FRANCE ANJ CLARIFIES EVIDENCE EXPECTATIONS FOR OPERATORS DEALING WITH PLAYER FRAUD

France’s gambling regulator, the Autorité Nationale des Jeux (ANJ), has published a practical guide for licensed online gambling operators on identifying, documenting and responding to player fraud.

The guide does not introduce new legal obligations. It instead clarifies how existing anti-fraud and anti-money laundering requirements should be applied in practice, including when operators may close accounts, withhold balances, cancel bets or redistribute prizes.

A key focus is the evidence operators need before taking action against players.

Fraud categories covered

The ANJ identifies six main types of fraud encountered in online gambling: identity fraud, payment fraud and abusive chargebacks, in-game cheating, money dumping and manipulation of sporting events.

For each category, the guide sets out the relevant legal framework and practical measures operators can take.

In cases of identity fraud, operators can close an account once fraud has been established and may reserve funds where ownership of the linked bank account cannot be confirmed.

For account takeovers, the ANJ highlights technical safeguards including two-factor authentication for withdrawals and changes to banking details.

The guide also addresses poker collusion and the use of bots. Operators can include contractual provisions allowing illegitimate winnings to be redistributed to affected players. The ANJ notes that French courts have accepted such measures where operators can support their decisions with robust evidence.

Evidence rather than suspicion

The strongest message from the guide is that operators should not act on suspicion alone.

The ANJ refers to the concept of faisceaux d’indices, or a combination of indicators, which French courts have accepted in previous cases. These can include IP addresses, device information and connection timings.

This puts greater emphasis on the quality and retention of evidence behind an operator’s decision. Operators are advised to maintain detailed records, review their terms and conditions and ensure that fraud detection procedures are supported by appropriate technical controls.

The guidance also calls on operators to review their KYC and fraud prevention processes and check that their technical safeguards remain consistent with regulatory and certification requirements.

Part of wider compliance focus

The fraud guidance comes as player protection remains a wider priority for the ANJ.

In July, the regulator fined an unnamed online betting operator €500,000 after finding failures in the identification and support of customers showing signs of problematic gambling. The investigation found that 29 high-risk players had not been correctly identified, including six who were missed entirely.

The regulator has also continued to focus on gambling risks around major sporting events, including through a public awareness campaign launched during the 2026 World Cup.

The new fraud guide adds another layer to this approach, but its immediate significance for operators is practical: where action is taken against a player, the evidence supporting that action needs to stand up to scrutiny.