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The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.

It requires operators to describe in detail how they will responsibly wind down their operations should their licence not be renewed or be revoked. Or if they decide to leave the market midway through the five years between renewals.

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They included tampering with a witness, lying to probation officers about a cell phone, illegally recording a phone call, maintaining a concealed “sex room” inside his home, failing a drug test, and associating with a convicted felon.

Navarro told Rashid she doubted his claims of rehabilitation, saying she was “very disappointed” and “not sure I believe” he is a changed person.

Navarro noted during Thursday’s hearing that she had not presided over Rashid’s original plea agreement and had previously expressed concern that the deal did not fully reflect the severity of his conduct.