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In cases of identity fraud, operators were advised to close accounts upon establishing fraud and to reserve balances when bank account ownership cannot be confirmed.
Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.
For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.
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“Whether it’s a 10-person or 100-person fund, they log in through the same Google email and share the same login credentials, which makes no sense,” he said.
ParlayX is developing individual logins, delegated permissions and subaccounts for such teams. Other gaps include unified execution across exchanges, prime brokerage and common resolution standards.
A contract purchased on Kalshi cannot simply be transferred and sold on Polymarket, even where the two markets appear to cover the same outcome. Each exchange may also define and resolve its contracts differently, creating an additional risk for firms trading across venues.
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He was also fined $71,356.
Kalshi’s compliance department uncovered a series of large trades made by Santos throughout February 2026 involving contracts that would pay out based on whether he attended the State of the Union address on 24 February.
The exchange reported that Santos then issued public statements regarding his attendance, some deemed false or misleading, that were deliberately aimed at influencing the price of “Yes” or “No” contracts connected to his attendance.