If you are saying that you made the OP whole again by sending his deposit back but not his winnings then that is something that is something the majority of the community here will not be able to accept as an appropriate outcome. Kindly reconsider.
Maybe the way forward in this case would be to simple send the full winnings to the OP then enforce your VPN policy strictly enough to stop users depositing and signing up therefore you cannot use VPN as an excuse when users want to withdraw.
I hope you reassess the situation, pay the OP what he is owed then we can all move forward.
ToS have been violated after the activity on his 2nd deposit(usage of VPN). We decide to refund the deposit from the 2nd deposit (37 mBTC).
The player has been contacted also on his Email. After this, we consider the case solved.