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“It would be crazy to say that these cases are positive for the industry,” he says. “They will no doubt continue, but as an industry we need to try to reduce their frequency.”

Enforcement publicity may lack context, and some settlements may involve errors rather than systemic recklessness. But the sector cannot control how its opponents use these cases. It can only reduce the supply.

At a moment when the industry needs to persuade politicians that regulated gambling is capable of managing risk responsibly, repeated failures in long-established areas such as AML and safer gambling amount to political self-harm.

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Spectrum conducted follow-up interviews with these employees who had “provided derogatory information relating to Evolution’s business practices”.

It said all interviewees had cooperated fully and some of them had “virtually little or no familiarity with the allegations contained in the report, as their job responsibilities fall outside the scope of these matters”.

Kugler told Spectrum “it was never his intention to provide incriminating information”. He said he had felt duped by Black Cube, and noted the person he had met with had disappeared after the report was released. He believed they had used a fake identity.

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Touch Sokhak, deputy spokesperson of the Ministry of Interior, emphasised that the operation seeks to prevent Cambodia from becoming “a safe haven or money-laundering base for technology-related criminals”.

However, the sustained enforcement drive has already taken a toll on the wider Cambodian economy. In May, the government lowered its 2026 GDP growth forecast as construction, real estate and consumer spending absorb the short-term impact of the crackdown.

Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements.