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This required operators to subject players to rigorous checks before signing up new VIPs, including having their betting behaviour being closely monitored.
Operators were also banned from incentivising customers based on losses, and reward programmes must be overseen by senior management. The code restricts any player under the age of 25 from taking part.
According to a GC report from 2025, the number of VIP customers in the market had dropped by 95% per operator since the strengthening of restrictions.
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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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Skyhills is the third illegal operator targeted by Nederlandse Loterij, with prior legal action taken against Lalabet and Qbet.
The Lalabet case, which reached a milestone in June, saw a Dutch court rule largely in favour of the lottery operator.
It found Lalabet’s operators and directors had acted unlawfully by targeting Dutch players and ordered them to cease activities and provide detailed ownership and shareholder information.
