Golden Fish

What is Golden Fish?

These internal changes form part of wider organisational shifts following Veikkaus’ May 2026 decision to establish two subsidiaries: one dedicated to exclusive operations and another for the newly competitive, licence-based market.

Veikkaus has submitted licence applications as a private entity, joining around 50 other companies that had applied to join the upcoming market by the end of June.

The company committed to a management reshuffle late last year as part of this transition, scrapping the role of deputy CEO after Velipekka Nummikoski was shuffled into a new role.

How to play Golden Fish

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.

Within its investigation Black Cube named a number of Evolution employees which it had interviewed and reported to have provided information on the company that supported the intelligence firm’s claims.

What is Golden Fish?

For enforcement authorities, however, the challenge is not simply estimating its size. It is keeping track of an ecosystem that can continually change domains, infrastructure and acquisition channels. That is where Madsen sees Trace2Trace fitting in.

One of its investigations concerns a specific globally renowned brand. Madsen says an initial scan identified around 1,600 domains, followed by another roughly 4,500 associated with this operator. That puts the number identified so far at around 6,000, although he believes the actual figure is considerably higher. “I think what we’ve found so far is only a small part of the overall picture,” he says. “I’m almost certain the real number is at least twice as high.”

Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.