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“What I saw is, Holland Casino is a company with 4,000 people working in hospitality, in a strongly regulated market where you have to balance between offering entertainment and a nice evening out with hospitality, and the risk attached to that – and there you see the similarities with the airline industry.

She adds: “For example, Transavia also had 4,000 people, cabin crew, cockpit, and more, all very regulated, labour union intensive, people being busy with what can we offer to the guests – but at the same time they have to know their rules and their regulations very well, because it’s important when there’s risk attached.

“I had never been a CEO before so I came to it with a kind of Pippi Longstocking attitude – ‘I’ve never done it, but I’m sure I can do it!’”

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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.