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About Surf Zone
The report was commissioned by Evolution and was recently unsealed in the ongoing case. Evolution had tried to delay the report’s release, citing confidential and commercial sensitivity.
The case, which dates back to November 2021, was filed by Evolution against Black Cube, after the intelligence firm was found to have been secretly investigating Evolution’s activities from December 2020.
Playtech commissioned Black Cube’s investigation, which Evolution has described as a “smear campaign” involving secretly recorded interviews with staff members.
About Surf Zone
“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.
“The fact that suspension has been considered necessary in this case therefore indicates that the Commission presently considers the issues sufficiently significant to justify preventing the operators from continuing to offer gambling while its reviews are ongoing.”
For any consumer-facing businesses, a suspension is likely existential and such appears to have been the case here. But wider implications have to be considered before the two sites are binned forever.
What is Surf Zone?
The Commission launched its investigation into various reports of insider betting on the election date in June 2024 after Ladbrokes flagged a bet placed by Williams, who was recorded as a politically exposed person.
Further bets flagged by operators involved other politically sensitive individuals, including Metropolitan Police officers and political advisers. The Commission charged 15 people total in April 2025. Four have now pleaded guilty.
The offences relate to special betting markets that let customers wager on the exact date of the general election.