MiFinity Compliance Report
High-Risk Payment Processing, Illegal Offshore Casinos, and a Non-Transparent Group Structure
A detailed compliance review conducted by Scam-Or Project documents that MiFinity, a regulated Electronic Money Institution holding licenses from the FCA (UK) and MFSA (Malta), has been systematically processing payments for offshore online casinos operating without authorization in the UK and across the EU.
The group’s 2024 financial statements disclose a dramatic 307% surge in net income, reaching £8.6 million, coinciding with a rapid expansion into high-risk gambling merchants. At the same time, the accounts reveal more than £22.6 million in internal fund movements routed through affiliated entities with limited transparency.
Beneficial ownership remains unclear, and the death of founder Mike Busher in summer 2024 removed the primary individual with first-hand knowledge of the group’s historical offshore structuring.
Executive Summary
Scam-Or Project Intelligence has completed an extensive compliance assessment of the MiFinity Group, a cross-border payment processor licensed in the United Kingdom and Malta. The investigation identifies persistent regulatory and compliance weaknesses, summarized below.
Key Findings
1. Systematic Facilitation of Illegal Online Gambling
MiFinity has been identified as a core payment processor for multiple offshore casino operators that target regulated markets without holding the required local gambling licenses.
Documented examples include:
- Legiano Casino — Licensed in Anjouan/Curaçao, yet actively accepting players from the UK and EU without national authorizations
- Winning.io — Curaçao-licensed operator enabling global payments, including transactions from restricted jurisdictions
- Scale of exposure — Evidence of MiFinity payment services appearing across 650+ gambling websites, many lacking proper regulatory approval
Regulatory context:
UK Gambling Commission rules and EU national gambling regulations require payment institutions to block or refuse merchants that operate without local licenses. The documented processing of payments for Legiano and Winning.io directly conflicts with these obligations.
2. 307% Revenue Growth Aligned With High-Risk Merchant Expansion
| Indicator | 2023 | 2024 | Change |
|---|---|---|---|
| Net Income | £2.1M | £8.6M | +307% |
| Total Assets | £23.2M | £77.0M | +231% |
| Gross Margin | — | 52.1% | Far above industry norm |
Key observations:
- A 52.1% gross margin significantly exceeds the typical 2–5% range seen among low-risk, fully compliant payment processors
- The growth spike followed the October 2023 appointment of Jim Purcell, former CFO of EBET Inc., as Chief Operating Officer
- The margin profile strongly suggests premium pricing for high-risk merchants unable to access traditional banking rails
Compliance interpretation:
Such margins are consistent with a “processor of last resort” model, servicing merchants excluded by mainstream financial institutions due to regulatory risk.
3. £22.6 Million in Non-Transparent Inter-Company Transfers
The 2024 audited accounts disclose extensive internal transactions lacking clear economic justification.
| Payment Flow | Amount (GBP) | Description |
|---|---|---|
| MiFinity UK → Concentric Data Services (Ireland) | £6.8M | “Service & Technology Fee” |
| MiFinity Malta → MiFinity UK | £14.4M | Payable due (purpose undisclosed) |
| MiFinity Payments (Ireland) → MiFinity UK | £1.4M | Payable due (purpose undisclosed) |
| Total | £22.6M+ | Undisclosed inter-company dependencies |
Compliance concern:
The £6.8M annual payment to Concentric Data Services, an unregulated entity with no publicly described operational scope, raises serious questions about the outsourcing of sensitive functions such as merchant onboarding, AML screening, or transaction monitoring outside regulatory supervision.
Original MiFinity Financial Analysis.
4. Opaque Ownership and Governance Structure
- Ultimate Beneficial Owners: Not publicly disclosed
- Named controllers:
- Paul Kavanagh — Chief Executive Officer
- Kieron Nolan — Chief Financial Officer
- Founder:
- Mike Busher (b. 1951, US national), former majority shareholder (>75%), deceased in an aircraft accident in summer 2024
Additional red flags:
- Busher appears in the ICIJ Offshore Leaks (Paradise Papers) as a shareholder in Concentric Data Services Malta Ltd, confirming historical offshore linkages
- MiFinity Payments Limited (Malta) functions as the group holding entity yet provides no consolidated public financial reporting
5. Regulatory Arbitrage via Multi-Jurisdictional Design
The group structure appears optimized to exploit differences in supervisory rigor:
- Merchant onboarding routed through Malta (MFSA)
- Payment execution and banking access via UK (FCA)
- Technology and support functions outsourced to Ireland through an unregulated entity
- Holding and ownership opacity maintained at the Maltese parent level
Result:
This configuration creates structural blind spots, allowing high-risk merchants to be onboarded under weaker oversight while still accessing UK and EU financial infrastructure.
Overview of the Full Compliance Report (2026 Edition)
The complete 26-page MiFinity Group Compliance Report covers:
Part 1 — Corporate Structure
Mapping of seven entities across four jurisdictions and analysis of £22.6M in internal fund flows.
Part 2 — Beneficial Ownership & Key Individuals
Profiles of Kavanagh, Nolan, the late founder Busher, COO Jim Purcell, and Franklin Cachia (Chief Compliance Officer, also affiliated with CSB Group).
Part 3 — Business Model & Merchant Exposure
Detailed examination of MiFinity’s gambling-focused merchant portfolio, including case studies of Legiano and Winning.io.
Part 4 — Regulatory Framework & Oversight Gaps
Assessment of FCA (Reg. 900090) and MFSA (Reg. C64824) supervision, highlighting the absence of visible group-level AML/CFT controls.
Part 5 — Compliance Hypothesis
The 307% growth in 2024 is directly linked to aggressive onboarding of offshore gambling operators unable to secure compliant payment services elsewhere.
Part 6 — Structural Red Flags
- Multiple entities with unclear operational roles
- Historical offshore links confirmed by Paradise Papers
- Founder death eliminating a key source of ownership transparency
- Ireland–Malta–UK routing enabling regulatory arbitrage
Part 7 — Findings & Enforcement Recommendations
Potential actions involving:
- UK Gambling Commission
- Financial Conduct Authority (FCA)
- Malta Financial Services Authority (MFSA)
- UK National Crime Agency
- EU Financial Intelligence Units
Compliance Risk Assessment
Overall Risk Level: CRITICAL
| Risk Area | Rating | Supporting Evidence |
|---|---|---|
| Merchant Due Diligence | CRITICAL | Processing for Legiano & Winning.io |
| AML/CFT Controls | CRITICAL | Lack of public policies; outsourcing to unregulated entity |
| Beneficial Ownership | CRITICAL | UBOs undisclosed; offshore opacity |
| Transfer Pricing & Fund Flows | HIGH | £22.6M unexplained internal transactions |
| Consumer Protection | HIGH | Facilitation of unlicensed gambling |
| Regulatory Coordination | HIGH | No visible group-wide AML/CFT framework |
| Financial Crime Exposure | MEDIUM-HIGH | Transaction patterns consistent with laundering typologies |
Enforcement urgency: Immediate regulatory scrutiny is warranted.
Call for Whistleblowers
Scam-Or Project invites current or former MiFinity employees, merchants, partners, and compliance professionals to submit relevant information via the Scam-Or Project whistleblower section.
All submissions are handled confidentially and may be forwarded to appropriate regulatory or law-enforcement authorities where justified.
About This Report
Scam-Or Project Intelligence specializes in investigations into financial crime, payment-system abuse, and high-risk fintech operations.
This report reflects six months of independent research, financial analysis, and regulatory review.
Prepared by: Scam-Or Project Intelligence Unit
Date: January 2, 2026
Distribution: Regulators, law-enforcement bodies, media partners, compliance professionals
