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The regulator concluded that the central figure’s youthful facial features, casual styling and excited demeanour gave the impression he was in his late teens or early twenties.
As such, the ad violated rule 16.3 of the CAP Code (Edition 12).
Midnite’s operator, Dribble Media Ltd, stated that the ad had not been authorised by their company. They cited discrepancies in branding and asserted that it was created and disseminated by an affiliate, Limay Media Ltd, without Midnite’s approval.
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Rather than a crackdown across the board, what emerged was a more regulated renewal framework.
Of the KSA’s update, Fuchs said: “If you [as an operator] have a clean sheet, there are some hoops, but for various modules you can just send a declaration which states that you’re compliant.”
He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.