Scratcher & Clicker

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The review examined the gaming sector and associated money laundering, terrorist financing and proliferation financing risks.

Spillemyndigheden said it contributed actively to this work and sat on FATF’s gaming sector working group. The regulator confirmed that many of the indicators in the report carry relevance for operators licensed in Denmark.

FATF’s warning on illegal and offshore gambling will resonate in Denmark. Last year, Spillemyndigheden secured a court order to block 178 unlicensed gambling sites, the largest such action in the regulator’s history. 

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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.