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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.

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.

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By December 2025, Kemorwale said gambling revenue had exceeded P700m, and the Authority expected the industry to surpass P1 billion by the end of the 2026/27 financial year in March 2027.

Kemorwale said Botswana needed to modernise oversight as the sector developed, including through a central electronic monitoring system and stronger enforcement capability. “Truth be told, this industry is evolving as the sun rises. You snooze, you lose,” Kemorwale said. He added that the Authority still relies on outside specialists for some technical regulatory work because domestic expertise is limited.

Illegal betting remained a central enforcement concern. In December 2025, the Gambling Authority and Financial Intelligence Agency were reported to be investigating eight foreign-based betting websites allegedly using local proxies to operate in Botswana.