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Even so, suspension is an unusually forceful intervention.

“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.

“The fact that suspension has been considered necessary in this case therefore indicates that the Commission presently considers the issues sufficiently significant to justify preventing the operators from continuing to offer gambling while its reviews are ongoing.”

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Shortly after his release, Santos had begun working as an influencer for Polymarket. 

Santos’ case represents the most severe among four disciplinary settlements announced by Kalshi, which has faced increasing scrutiny concerning insider knowledge risks and event outcome influence by market participants.

Santos is not the only individual disciplined for trying to game the prediction market system. Ben Midgley, a Republican candidate for the governorship of Maine, admitted purchasing under $1,000 worth of contracts related to his campaign. He accepted a $5,434.30 fine and a three-year suspension.

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Scotts Valley has maintained that federal officials reversed course under intense political pressure from the Yocha Dehe Wintun Nation, a neighboring tribe that opposes the Vallejo casino development.

During Friday’s hearing, McFadden appeared skeptical that Scotts Valley had met the rigorous legal standard required to demonstrate irreparable harm. He has not yet issued a ruling on the preliminary injunction request.

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