5 Mariachis

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“I sometimes wish regulators would look at other cases,” he adds. “I mean, what happened in Germany, what’s happening in the UK.”

This risk is particularly apparent when many offshore operators are established brands rather than unknown entities.

“It’s not a dark alley,” he continues. “It’s a large operator that’s regulated in other places, so it’s not the risk for the player that sometimes is implied.”

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Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.

Madsen says investigators can also examine how sites appear from different jurisdictions. If a site is presented in a country’s local language, for example, that can indicate that the market is being targeted. The next question is whether the operator has the necessary licence.

The same intelligence can be useful to gambling companies and suppliers that want to monitor where their products are appearing. Madsen says Trace2Trace currently has a client that fits that description, although he cannot disclose its identity.

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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.