ANJ Releases Guidance on Player Fraud Detection and Response for Licensed Operators

France’s Autorité Nationale des Jeux (ANJ) has published a guide instructing licensed gambling operators on identifying and responding to player fraud. The document functions as a compliance aid that supplements existing rules rather than creating new ones.

The guide applies to all gambling offers requiring online player registration, such as sports betting, online lottery, and network gaming tied to player accounts. It excludes activity limited to physical distribution networks with no online sign-up. ANJ prepared the material following consultation with licensed operators and the gaming ombudsman, as reported by Yogonet International. It references obligations under Article L. 320-4 of the Code de la Sécurité Intérieure and the third paragraph of Article 18 of the May 12, 2010 law governing sector competition. The guide supplements standards in the September 9, 2021 framework for combating fraud and money laundering.

Five Fraud Categories and Practices Left to Contract

ANJ sets out five categories of player fraud: civil identity fraud, payment method fraud, abusive bank chargebacks, game-related fraud such as poker collusion and betting manipulation, and “money dumping” in which funds move between accounts disguised as poker chip transfers. The typology is explicitly non-exhaustive.

Operators flagged several practices during consultation, including betting bots, betting syndicates, late bets, and repeated account opening and closing for bonus purposes. ANJ declined to classify these as fraud, leaving their treatment to each operator’s contractual terms and case-by-case analysis. Operators retain contractual freedom throughout.

Evidentiary Thresholds and Actions for Confirmed Fraud

Operators cannot refuse to pay winnings or return an account balance on suspicion alone. A player’s failure to respond to inquiries may reinforce suspicion but does not itself constitute proof. The guide reviews case law to illustrate the evidentiary bar courts apply in disputes.

For confirmed fraud, the guide clarifies actions required under current law or offers recommendations on handling the account and balance, including hacked accounts and falsified bank details. It closes with recommendations on penalty clauses, grounded in referenced legal texts and case law.

The guidance highlights a limitation: its non-binding nature leaves room for differing operator interpretations and potential disputes over what constitutes adequate evidence. French operators should therefore review their existing anti-fraud procedures against the described thresholds to reduce exposure in regulatory reviews or court challenges.

Reporting: Yogonet International

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