Gerards Gambit

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This required operators to subject players to rigorous checks before signing up new VIPs, including having their betting behaviour being closely monitored. 

Operators were also banned from incentivising customers based on losses, and reward programmes must be overseen by senior management. The code restricts any player under the age of 25 from taking part. 

According to a GC report from 2025, the number of VIP customers in the market had dropped by 95% per operator since the strengthening of restrictions. 

About Gerards Gambit

Playtech on Wednesday published a statement highlighting what it claimed were compliance failures at Evolution, written into the Spectrum report.

Within the report, Spectrum alleged “concerns around the availability of Evolution’s games in certain prohibited markets, the regulatory implications of its practices, and the lack of proactive monitoring of its customers”.

However the report confirms that Spectrum did not believe Evolution had engaged in any illegal practices. 

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The court also explored potential liabilities for trust administrators and local representatives who facilitate illegal gambling sites. 

While it did not find Curaçao-based trust firm DECC and its directors liable in this case, the ruling signalled that closer scrutiny of such intermediaries could unfold.

Nederlandse Loterij has announced plans to appeal portions of the Lalabet decision, particularly arguing that trust firms have a duty to properly vet their clients.