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“Evolution may be unwittingly susceptible to having its games played through third-party operators, in violation of its contracts…”

The firm goes on to confirm that Evolution had therefore received income from these unauthorised activities.

“Such operations, albeit not purposeful, may impugn the company’s reputation and potentially subject Evolution to heightened regulatory scrutiny and the imposition of sanctions,” the report continues.

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“If we just sold the data to Kalshi in order to list the markets but no one was coming in and placing liquidity, there’s no point in them listing the markets,” Monk said. “We also need to supply the data to the market makers to inform their models.”

Catalist initially received a list of fewer than 10 potential market makers from Kalshi. It has since completed agreements with close to 20 and is engaging with approximately another 20.

That growth reflects the expanding number and variety of sports contracts. ITF tennis is particularly dependent on official data because its more than 60,000 annual matches are not generally televised. Unofficially monitoring a tour moving between locations such as Bogotá and Bali would be difficult, Monk noted.

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“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.

He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.