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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.
In March, courts in London and Dubai imposed a worldwide freezing order on Raja’s assets up to £1.3 billion.
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“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.
He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.
“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.
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The growth, driven predominantly by remote (online) gambling activities, contrasts with a decline in physical gambling premises, highlighting shifting consumer preferences and market dynamics.
When excluding all reported lottery activity, GGY increased to £13.2 billion, up 4.7% year-on-year.
Remote casino, betting, and bingo activity was the standout channel, generating £8.3 billion in GGY, a 6.9% year-on-year increase and accounting for approximately 63% of the non-lottery industry yield.