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The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.

Operators were encouraged to take several practical steps, including enhancing terms and conditions, maintaining robust evidence and uptaking technical standards.

They have also been advised to thoroughly review their Know Your Customer, fraud detection protocols and contractual terms to reflect the guide’s recommendations. 

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“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.

In the dossier, Spectrum unpacks Evolution’s review and vetting processes for potential clients. At the time of the report, Evolution required clients to provide certification of the beneficial ownership of 25% or more of the company. But Spectrum says it was not using “a viable process” as some documents provided by companies could be inaccurate.

“If red flags become known to Evolution during this onboarding process, Evolution should either determine not to do business with the company or undertake enhanced due diligence to resolve the red flags before engaging in business with the company,” Spectrum advises.

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Grasso claimed he was unaware of the donations before being approached by Patch. He added that his campaign had reported them to the Board of Elections and would be returning them.

It was not the first time Grasso had returned campaign money from Rovito.

The restaurateur donated $5,000 to Grasso’s unsuccessful 2018 campaign for Illinois attorney general in November 2017, but Grasso returned the money the following month after a TV station questioned the contribution, according to Patch.