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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.

“Kugler’s position is that Evolution does not supply games to Iran. He stated that “I know we have players in Dubai”, Spectrum notes, in response to Black Cube’s claims.

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Products offered to the public must undergo prior evaluation by a competent body of the Federal Executive Branch, to be defined in regulations. Products classified as high-risk will be subject to specific harm reduction measures. Products with excessive risk may not be offered. This category includes products with outcomes determined by random mechanisms, continuous cycles and variable rewards, such as roulette, slot machines, collision games and simulated virtual sports. 

Furthermore, the text maintains obligations for monitoring and institutional cooperation, with the provision of aggregated and anonymised data to the competent authorities. It also provides for actions by the executive branch aimed at monitoring the impacts of betting, training health professionals, updating care protocols and periodically disseminating information on the effects of the activity. 

Application providers, digital platforms, hosting services and media intermediaries must remove irregular advertisements and campaigns after notification from the competent authority. The rapporteur’s version requires that the notification clearly and specifically identifies any content deemed irregular and ensures the right to a fair hearing and full defence. Journalistic, academic, parliamentary, artistic and opinion content are expressly protected.