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“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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Not a single newspaper reference to Naked City appears in a Las Vegas newspaper before a June 20, 1982, Las Vegas Review-Journal cover story headlined: “’Naked City’ a Las Vegas Battleground.”

In that story, Lt. John Conner reported investigating 10 killings in the neighborhood in 16 months. “Most of them appear to be drug-related,” the homicide chief said.

The Meadows Addition—”Las Vegas” is Spanish for “the meadows”—was created in the late 1940s as a grid of 16 streets named after other cities, including New York, Chicago, Cleveland, St. Louis, and Philadelphia. Before the Sahara opened in 1952, Sahara Avenue was wholly contained in this community, where it was known as San Francisco Street.

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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.