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“There are significant checks on individuals and businesses before a licence is granted,” he says. “The UK Gambling Commission has set out what it expects. If you want a licence in the UK, you need to meet those expectations.”

Bentley believes regulated operators are genuinely trying to do the right thing but says some mistakes could be mitigated through better automation and continuous monitoring. Enforcement statements also provide lessons that businesses should use to test their own exposure.

“It would be crazy to say that these cases are positive for the industry,” he says. “They will no doubt continue, but as an industry we need to try to reduce their frequency.”

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Raja denies wrongdoing and maintains there was no fraud or dishonesty.

MFS operated as a non-bank lender—often termed a “shadow bank”—that borrowed funds from institutional investors to finance property loans for its clients.

The company experienced rapid expansion prior to its collapse, with its loan book reaching approximately £2.4 billion ($3.2 billion) by the end of 2024. Its creditors included major international financial institutions and private equity firms.

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“In our judgment, Evolution’s ineffective compliance procesures have allowed these situations to develop and therefore need prompt reevaluation and enhancement in order to comply fully with the terms of the contracts,” the report reads.

“Evolution may be unwittingly susceptible to having its games played through third-party operators, in violation of its contracts…”

The firm goes on to confirm that Evolution had therefore received income from these unauthorised activities.