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The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.
“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”
Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.
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The conflict stems back to January 2025, when the outgoing Biden administration initially determined that the Vallejo parcel was eligible for gaming.
Interior temporarily rescinded that determination just two months later after newly appointed Secretary Doug Burgum raised concerns over whether the tribe’s historical connection to the land had been thoroughly evaluated.
Scotts Valley filed suit in response. In October 2025, Judge McFadden ruled that Interior had violated the tribe’s due process rights by rescinding the approval without giving prior notice or an opportunity to respond.
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Another claim made by Black Cube’s report was that Evolution had accepted wagers in virtual currencies and cash. Spectrum confirms that wagers were made by end users using crypto currencies, however it was the operator, and not Evolution accepting these bets.
After assessing part of a 75-page PDF spreadsheet of transactions provided by Evolution, Spectrum found crypto wagers had been placed on Evolution games provided by Hub88, as alleged by Black Cube.
Up to 1,124 occurrences of virtual currencies being used were discovered by Spectrum, which added up to 11.5% of the sessions included in the spreadsheet provided by Evolution.