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“Here’s an API. Bernard and 88 other people can market-make all these request-for-quotes (RFQs),” Marantelli says. “Some people might come in and just do esports because they’re esports experts. Others do everything. Some focus on same-game parlays. But it’s a sportsbook.”

The institutional layer is largely invisible to customers presented with a P2P proposition. Retail users may technically trade against one another, but the depth required by a mass-market product cannot be supplied by occasional customers alone. Professional firms must be prepared to quote continuously and commit substantial capital.

Marantelli says the London-based White Swan is a significant market maker on several secondary exchanges, accounting for as much as 40% of activity on some platforms. Its particular focus is the RFQ, parlay market.

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“Therefore, we have been having this debate,” he added. “I have been to Congress, the Supreme Federal Court, and the Attorney General’s office to talk about the impact of betting on the lives of Brazilians.

“We have made progress, such as increasing the direct tax to 15% and including the activity in the Selective Tax. Those benefiting from social programmes and those who joined the Desenrola programme were also prohibited from betting.”

He also pointed to the self-exclusion mechanism adopted by the government.

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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.