MIFINITY COMPLIANCE REPORT: HIGH-RISK PAYMENT PROCESSOR, ILLEGAL OFFSHORE CASINOS & OPAQUE GROUP STRUCTURE

Reg Techer
Fri, 02 Jan 2026 09:01:13 +0000
Compliance, FCA, High-risk payment processors, Malta Financial Services Authority, ticker, Trending, Concentric Data Services, Kieron Nolan, Legiano, MiFinity, MiFinity Malta, MiFinity UK, Mike Busher, Paul Kavanagh, Winning, Winning.io

FinTelegram Intelligence has completed a comprehensive compliance review of the MiFinity Group, a multi-jurisdictional payment processor operating with regulatory licenses in the United Kingdom (FCA) and Malta (MFSA). The investigation reveals the MiFinity's massive involvement in illegal gambling and an opaque group structure.

In a comprehensive compliance investigation, FinTelegram has documented that MiFinity—a regulated Electronic Money Institution operating under FCA and MFSA licenses—is systematically facilitating payments for unlicensed offshore casinos operating illegally in the UK and EU. The 2024 financial statements reveal a 307% explosion in net income (to £8.6 million), driven by aggressive expansion into high-risk gambling merchants. Simultaneously, the group has concealed £22.6 million in undisclosed inter-company flows to unregulated support entities. The underlying beneficial ownership remains opaque, and the death of founder Mike Busher in summer 2024 removes the primary witness to the group’s offshore structuring.

EXECUTIVE SUMMARY

FinTelegram Intelligence has completed a comprehensive compliance review of the MiFinity Group, a multi-jurisdictional payment processor operating with regulatory licenses in the United Kingdom (FCA) and Malta (MFSA). The investigation reveals:

KEY FINDINGS

1. Documented Illegal Gambling Facilitation

MiFinity is a primary payment processor for offshore casinos operating illegally in regulated markets:

Legiano Casino: Licensed in Anjouan/Curacao, illegally accepting UK and EU players without local gambling licenses

Winning.io: Curacao-licensed operator facilitating global payments including to restricted jurisdictions

Documented presence across 650+ gambling websites, many operating without adequate local licensing

Regulatory Violation: UK Gambling Commission and EU national gambling authorities require payment processors to refuse merchants operating without local licenses. MiFinity’s facilitation of Legiano and Winning.io violates these regulatory obligations.

2. Explosive 307% Growth Correlated with High-Risk Merchant Expansion

Net Income (2024): £8.6 million (+307% YoY from £2.1M in 2023)

Total Assets (2024): £77.0 million (+231% YoY from £23.2M in 2023)

Gross Profit Margin (2024): 52.1% (compared to 2–5% standard for legitimate payment processors)

Timing: Growth explosion immediately followed the October 2023 appointment of Jim Purcell (former CFO of EBET Inc., a gaming operator) as Chief Operating Officer

Compliance Insight: The anomalously high gross margin (52.1%) indicates premium pricing for high-risk merchants—casinos unable to access banking rails through legitimate processors. This is consistent with a business model targeting “merchants of last resort.”

3. £22.6 Million in Undisclosed Inter-Company Flows

The 2024 audited financial statements reveal massive inter-company transactions without transparent business rationale:

Payment Direction | Amount (GBP) | Nature
MiFinity UK → Concentric Data Services (Ireland) | £6.8 million | “Service & Technology Fee” (79% of net income)
MiFinity Malta → MiFinity UK | £14.4 million | Payable Due (undisclosed purpose)
MiFinity Payments (Ireland) → MiFinity UK | £1.4 million | Payable Due (undisclosed purpose)
TOTAL | £22.6 million+ | Undisclosed interdependencies

Compliance Red Flag: The £6.8M annual fee to Concentric Data Services—an unregulated entity with no public business description—suggests outsourcing of critical compliance functions (merchant onboarding, KYC, AML/CFT) to an entity outside regulatory oversight.

Read the MiFinity Financial Analyses here.

4. Opaque Corporate Structure & Beneficial Ownership

Ultimate Beneficial Owners: Not publicly disclosed. While Paul Kavanagh (CEO) and Kieron Nolan (CFO) are identified as controllers, precise equity percentages and additional UBOs remain unknown

Founder Death: Mike Busher (American, b. 1951), founder and original majority shareholder (>75%), died in an aircraft accident in summer 2024. His death removes the key witness to the group’s 2017 control transfer and offshore structuring

Offshore Links: Busher is listed in the ICIJ Offshore Leaks (Paradise Papers) database as a shareholder of Concentric Data Services Malta Ltd, confirming historical use of offshore secrecy jurisdictions

Holding Company Opacity: MiFinity Payments Limited (Malta) serves as group parent but provides no public financial disclosures

5. Regulatory Arbitrage Through Multi-Jurisdictional Structure

The group exploits differences in regulatory stringency:

Merchant Onboarding in Malta (MFSA, historically permissive) → Execution through UK (FCA)

Technology services outsourced to Ireland (Concentric, unregulated) → Limited FCA/MFSA visibility

Holding company in Malta → Opaque beneficial ownership and transfer pricing

Result: The structure creates systematic gaps in regulatory oversight, allowing high-risk merchants to be onboarded in jurisdictions with weaker enforcement while accessing UK banking infrastructure.

FULL COMPLIANCE REPORT SUMMARY

The MiFinity Group Compliance Report 2026 provides a comprehensive 26-page analysis covering:

Part 1: Corporate Structure

Detailed mapping of the group’s seven entities across four jurisdictions, identification of the holding company structure in Malta, and analysis of the inter-company financial relationships totaling £22.6 million.

Part 2: Beneficial Ownership & Key Individuals

Profiles of current controllers (Kavanagh, Nolan), historical founder (Busher, deceased), and management team including Jim Purcell (COO, gaming sector background) and Franklin Cachia (Chief Compliance Officer, Malta, with dual role at consulting firm CSB Group).

Part 3: Business Activities & Merchant Exposure

Documentation of MiFinity’s explicit focus on online gambling, detailed case studies of Legiano and Winning.io (illegal offshore casinos), evidence of presence across 650+ gambling websites, and analysis of the compliance gaps that allow illegal operators to be onboarded.

Part 4: Regulatory Environment & Gaps

Analysis of FCA oversight (MiFinity UK, Reg. 900090) and MFSA oversight (Mifinity Malta, Reg. C64824), identification of group-level compliance gaps (no consolidated AML/CFT policy, undisclosed merchant screening procedures, opaque transaction monitoring), and evidence of regulatory arbitrage opportunities.

Part 5: Compliance Hypothesis

Hypothesis: The 307% 2024 growth is directly correlated with aggressive acquisition of offshore gambling merchants (specifically Legiano, Winning.io, Dama Group) that cannot access banking services through legitimate processors. The 52.1% gross margin reflects premium pricing charged to these high-risk merchants.

Evidence:

COO appointment (Oct 2023) from gaming sector immediately preceded growth explosion

Documented facilitation of illegal operators (Legiano, Winning.io)

Lack of compliance scaling proportional to 231% asset increase

£6.8M annual payments to unregulated support entity (Concentric)

Part 6: Corporate Opacity & Red Flags

Multiple entities with unclear operational roles receiving millions in payments

Paradise Papers link confirming historical offshore structuring

Deceased founder removing key witness to beneficial ownership

Ireland-Malta-UK jurisdictional structure enabling regulatory arbitrage

Minimal compliance infrastructure relative to transaction volume

Part 7: Summary Findings & Enforcement Recommendations

The report identifies critical compliance concerns requiring investigation by:

UK Gambling Commission: Illegal gambling facilitation

FCA: Merchant due diligence adequacy and AML/CFT controls

MFSA: Group-level compliance coordination

UK National Crime Agency: Money laundering risks

EU Financial Intelligence Units: Cross-border transaction patterns

COMPLIANCE RISK ASSESSMENT

Risk Level: CRITICAL

Risk Category | Assessment | Evidence
Merchant Due Diligence | CRITICAL | Documented facilitation of Legiano, Winning.io (illegal in EU/UK)
AML/CFT Adequacy | CRITICAL | No public disclosure of transaction monitoring, SAR filing, sanctions screening standards; Concentric outsourcing to unregulated entity
Beneficial Ownership Opacity | CRITICAL | Ultimate UBOs not disclosed; holding company in permissive jurisdiction; founder death removes witness
Transfer Pricing & Fund Flows | HIGH | £6.8M annual payments to unregulated entity lack business rationale; £14.4M inter-company payables undisclosed
Consumer Protection | HIGH | Facilitation of unlicensed gambling violates UK Gambling Commission regulations and harms consumers
Regulatory Coordination | HIGH | No evidence of group-level AML/CFT; multi-jurisdictional structure creates oversight gaps
Financial Crime Risk | MEDIUM-HIGH | Structure and transaction patterns consistent with money laundering schemes; opacity enables hidden beneficial ownership

Regulatory Enforcement Urgency: IMMEDIATE

The documented facilitation of illegal gambling operators (Legiano, Winning.io) constitutes a clear regulatory violation that should trigger:

1. Immediate investigation by UK Gambling Commission and FCA

2. Merchant compliance audit examining Legiano, Winning.io, and similar onboarding

3. Beneficial ownership disclosure request to Malta parent company

4. Concentric Data Services investigation regarding unregulated compliance functions

5. Transaction pattern analysis for money laundering indicators

DOWNLOAD THE FULL COMPLIANCE REPORT

[DOWNLOAD: MiFinity Group Compliance Report 2026 (PDF)]
26-page comprehensive analysis with detailed evidence, regulatory framework citations, and enforcement recommendations

Download the full MiFinity Compliance Report 2026 here.

CALL TO WHISTLEBLOWERS: SUBMIT EVIDENCE VIA WHISTLE42

FinTelegram is actively seeking information from MiFinity insiders, former employees, merchants, and partners regarding:

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FinTelegram will respect whistleblower confidentiality to the maximum extent possible while ensuring information reaches appropriate regulatory and law enforcement authorities for investigation and potential enforcement action.

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ABOUT THIS REPORT

FinTelegram Intelligence is a leading investigative organization specializing in financial crime, cryptocurrency compliance, and high-risk payment processor analysis. This compliance report represents 6 months of independent research, source verification, and regulatory analysis.

Report Prepared By: FinTelegram Intelligence Division
Date: January 2, 2026
Distribution: FinTelegram, Regulatory Authorities, Law Enforcement, Media Partners