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Within the report, Spectrum alleged “concerns around the availability of Evolution’s games in certain prohibited markets, the regulatory implications of its practices, and the lack of proactive monitoring of its customers”.

However the report confirms that Spectrum did not believe Evolution had engaged in any illegal practices. 

iGB is publishing the full 69-page report, which is accessible to registered users of the New Jersey court system, below for anyone to read.

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However, the latest filing does not create such a system right away. Its OIRA entry describes the action as a preliminary measure and says it is not economically significant under the relevant review criteria. No legal deadline has been listed for review either. 

It could, therefore, take quite a bit longer than the timing of the initial filing indicates. The CFTC would have to publish its action and solicit public comment after White House review before writing a formal proposed rule. Any final rule would have to undergo another review and comment period before it could take effect. 

The distinction matters for crypto businesses. The filing shows regulatory work is moving forward, but exchanges and other market participants cannot yet consider it a set of rules they must adhere to. 

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Madsen is clear that Trace2Trace does not shut websites down. Instead it tracks domains, identifies connections and documents changes so that regulators, enforcement authorities or other customers can use the information.

That distinction also informs his view of the wider battle. Asked whether illegal gambling can actually be defeated, his answer is: “No, but you can make it very difficult for them.”

The objective, he argues, is to make it harder for operators to simply replace a blocked domain with another one. “If they knew there was a tool that would find those new sites as well, they might become more cautious.”