CFTC-regulated exchange and prediction market Kalshi has begun to face scrutiny for its sports betting contracts, as well as questions about potential self-dealing among Kalshi entities (ESPN, Fast Company, Sportico). For the purposes of this question, "Kalshi" means Kalshi Inc., and "Kalshi affiliates" means Kalshi Klear LLC and Kalshi Trading (Kalshi - About, Kalshi - Kalshi Klear, Kalshi - Kalshi Trading). An announced investigation, including the issuance of a Wells notice or the disapproval of a contract, alone will not count (Yahoo, CFTC). The venue (i.e., type of court) and whether the enforcement action is administrative or injunctive are immaterial (CFTC - Office of the Director of Enforcement, CFTC - Enforcement Actions). The ultimate disposition of an enforcement action is immaterial.

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