France’s gambling regulator has published a practical guide for licensed online operators on how to identify, document and respond to player fraud. Issued on 31 August after talks with approved operators and the games mediator, the text is meant to guide day-to-day practice rather than create a new layer of law.
According to the Autorité nationale des jeux, the guide is an “outil de droit souple”, a soft-law tool that aligns operators’ conduct with existing rules while preserving contractual freedom. It applies to gaming offers that require online player registration, including competitive games, online lotteries and some networked physical-distribution products that open player accounts. It does not cover physical distribution networks with no online registration, and it leaves money-laundering and terrorist-financing suspicions to the separate rules that already govern those cases.
The guide also sits in a longer line of French compliance guidance. It builds on Article L.320-4 of the internal security code, which requires operators to help prevent fraud, and on a 2021 reference framework on fraud, anti-money laundering and terrorist financing. That earlier framework had already asked operators to organise themselves properly against fraud and to be able to justify their procedures and resources.
At the centre of the new guide is a non-exhaustive typology of player fraud. The ANJ lists civil-identity fraud, payment-mean fraud, abusive bank repudiation, in-game fraud and money-dumping as the main forms in scope. It also says operators should be able to characterise fraud without first filing a complaint or starting legal action against the player concerned.
The regulator is equally firm on evidence. It says operators should rely on probative elements, not suspicion alone, and it includes a review of case law on the standard of proof judges have accepted in disputes. The guide points to indicators such as IP addresses, device logs and connection timings, and says those elements should be assembled into a coherent picture before accounts are closed, balances are withheld or bets are cancelled.
The guide sets out responses for specific cases. For identity fraud, operators are told to close accounts once fraud is established and to reserve balances when ownership of the linked bank account cannot be confirmed. For account takeovers, it recommends technical safeguards such as two-factor authentication for withdrawals and for changes to banking details.
Some betting-edge practices are treated differently. The guide lists automated betting robots, collusion in sports or horse betting, late bets, manifest odds errors, offer-name errors and repeated account opening and closing for welcome bonuses as situations identified by the regulator but not classified as fraud in the guide’s own sense. In those cases, operators remain free to handle matters under their contracts.
An industry report on the guide said poker operators may also rely on contractual provisions to redistribute illegitimate winnings to affected players when collusion or bot use is supported by robust evidence. The ANJ, for its part, says operators should spell out as precisely as possible in their terms and conditions which player conduct will count as a contractual breach.
