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Each settlement involved cooperation with Kalshi’s investigation. 

What distinguishes Santos’ penalty is the exchange’s allegation that he actively issued false or misleading statements to alter prices and profited materially, violating additional rules such as failure to cooperate and manipulative conduct. 

These breaches escalated his sanction to a permanent ban and a significantly larger fine compared to others involved.

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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.

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Furthermore, the company sent 839 electronic messages to 165 individuals who had self-excluded, along with a further 2,000 push notifications to 45 customers without including the mandatory BetStop information.

ACMA’s investigation revealed multiple compliance breaches, primarily concerning account management and marketing controls. 

The regulator noted that several inactive accounts remained open long after users requested exclusion.