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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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“Japan is acting cautiously, after observing missteps from other jurisdictions. They are proceeding in the way that best suits them,” she adds.

The factor that led some operators to drop out of the licensing race could be the “uncertainty” created by regulations that “didn’t seem set in stone”, says Leckert.

“Some of them [investors] that were looking at Japan were looking at a big IR licence or nothing. With Tokyo and Yokohama being out of the mix, maybe some weren’t as interested anymore and decided to sit back, and wait and see how regulation and licensing shake out.”

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Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements. 

The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.

Initially framed as “Together Towards Disrupting the Chain and Ending Online Scams” by AKP in August, the conference now carries the theme “Acting Together towards Breaking the Chain and Eradication of Online Scams” on its official website.