Burning Diamonds

About Burning Diamonds

“If a customer finds black market sites that have all their preferred betting and gaming options, convenience dictates they will transfer a broad range of their expenditure there. Consumer recycling means that banning or restricting key products has a broader distortive impact on the entire market,” the report noted.

Notably for highly engaging verticals light online slots, if players are receiving a smaller-than-expected RTP (return to player), or bonuses have been restricted, they could again transition to an illegal offering where there are no such restrictions.

As has been flagged in previous reports, Regulus highlighted that the top 1% of active customers accounts for almost 50% of black market revenue across Europe. This follows a similar trend across licensed gambling as the report highlights “online gambling is a consumer discretionary expenditure item. This means a large proportion of expenditure is concentrated into a relatively small number of players.”

What is Burning Diamonds?

The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.

What is Burning Diamonds?

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.