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The UK’s Financial Conduct Authority (FCA) subsequently launched an enforcement investigation into MFS.
Raja’s appetite for high-stakes gambling predates his emergence as a prominent property lender. The Times reported last month that he was declared bankrupt in March 2005 with debts totaling around £350,000 ($470,000), a portion of which was owed to casino operators.
His bankruptcy was discharged a year later, though he remained subject to bankruptcy restrictions until March 2009. MFS was incorporated in November 2006 by Pratibha Dewan, who later became Raja’s wife.
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Rossi believes the ISC in Peru is an example of a government implementing new taxes without truly understanding how the industry works, and the potential impacts on channelisation to licensed offerings.
“Peru has been quite successful in channelling customers into the regulated framework,” Rossi comments. “The risk is that this channelisation can decrease in favour of the black market. We know the black market won’t have any consumption tax.
“There should be, in my opinion, a review of the whole ISC or consumption tax framework and find a kind of alignment or a better way to get an income in terms of taxes, but that should be balanced in order to avoid the disruption of businesses and a migration of customers to the illegal market.”
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In Sweden, Spelinspektionen recently flagged affiliates and social media as key channels for black market advertising and how affiliate networks redirect search traffic towards unlicensed operators.
Regulators have so far focused mainly on monitoring paid advertising. In Germany, the GGL credited an updated Google ad policy with reducing black market visibility. Yet, it acknowledged that illegal operators could still achieve visibility in organic search through SEO manipulation.
This points to a wider shift towards addressing organic search signals and domain-level practices such as doorway pages, an issue also raised in the UK, where research has linked black market migration to search-driven promotion and SEO exploitation.