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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.

The platform’s Rule 5.17(z), cited in all the matters, strictly prohibits trading in contracts where participants have decision-making power or can otherwise influence the underlying event, regardless of influence magnitude.

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In any event, successive regulatory tightening and tax increases have already created a “reasonably effective deterrent” to market entry.

There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.

“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.

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But while the ARGN intends to enhance collaboration between stakeholders across the continent, Akolade asserts the aim is to promote “common principles rather than identical regulations”.

Akolade explains: “Every African country has its own legal framework, culture, and level of market development, so a single model might not work everywhere.

“What we do believe is that basic principles should apply across all markets. These include protecting minors, providing effective self-exclusion options, promoting responsible advertising and ensuring that people affected by gambling harm can access support.