ANJ sets clearer standards for handling player fraud in France

France’s gambling regulator has published new guidance setting out how operators should deal with suspected player fraud.

The ANJ guide does not create additional legal obligations, but it gives firms a clearer framework for deciding when accounts may be closed, bets cancelled or balances withheld.

It also places evidence at the centre of those decisions. It warns that suspicion alone is not enough to justify refusing winnings or returning a player’s balance. The guidance follows consultation with licensed operators and France’s gambling ombudsman.

Guide covers five broad types of fraud

The guide applies to gambling services that require players to register online. This includes competitive online gambling, online lotteries and some gambling offered through physical networks where an account must first be opened.

It does not apply to entirely land-based gambling without online registration. Cases involving suspected money laundering or terrorist financing must also be handled under the separate rules governing those offences.

ANJ divides player fraud into five broad categories:

• Identity fraud, including false documents, account sharing and multiple accounts
• Payment fraud, such as using another person’s bank card
• Abusive chargebacks on deposits made by the player
• Gameplay fraud, including poker collusion, bots and sports manipulation
• Money dumping between poker accounts

The regulator also discusses practices that do not fall within its definition of fraud but may still breach an operator’s terms. These include late betting, exploiting obvious odds errors and repeatedly opening and closing accounts to claim bonuses.

Suspicion alone is not sufficient

The central message is that operators need evidence before taking action against a player.

ANJ states that an operator cannot refuse to pay winnings or return some or all of an account balance based solely on suspicion. A player’s failure to respond to questions may strengthen an operator’s concerns, but it does not prove fraud on its own.

An IP address or shared device may contribute to a case, but either may be insufficient in isolation. For example, ANJ notes that members of the same family connecting through one device does not automatically establish account sharing.

Operators may instead need several connected indicators. These could include common IP addresses and devices, similar betting patterns, matching payment details, closely timed account activity and inconsistent responses from the people registered as account holders.

"Operators must be able to demonstrate fraud, rather than relying on unusual activity or suspicion alone."

Previous court decisions have accepted account closures where several pieces of technical and behavioural evidence combined to show that multiple accounts were being controlled by the same person.

What happens to accounts and balances?

Where an operator has collected sufficient evidence, ANJ generally recommends closing accounts affected by fraud.

If a player has deliberately operated multiple accounts, this may include closing the account opened using their genuine identity as well as those created fraudulently.

The treatment of any remaining money depends on the type of fraud involved.

Where identity fraud means an operator cannot confirm that the nominated payment account belongs to the player, the balance should be placed in reserve rather than paid out.

Account takeovers require a case-by-case approach. If stolen funds have been moved to another player account but not withdrawn,  ANJ says the transfer should be reversed. If money has already been withdrawn because of a failure by the operator, the legitimate account holder may need to be compensated.

Bets connected to proven sports manipulation may also be cancelled. However, any legitimate money remaining in the account should normally be returned unless the operator can demonstrate that it is also connected to fraud.

Operators expected to review their procedures

ANJ described the document as a soft-law compliance tool rather than a new set of regulations. Nevertheless, it gives operators a more detailed benchmark against which their decisions could be assessed.

Companies may now need to review their account checks, payment controls, fraud-detection systems and record-keeping procedures. Their terms must also explain clearly when funds may be reserved, winnings redistributed or financial losses recovered from a fraudulent player.

The regulator said the guidance was designed to answer recurring questions from operators while bringing their practices into line with existing French law.