The Autorité Nationale des Jeux (ANJ) has published a guide instructing licensed gambling operators on how to identify and respond to player fraud, positioning the document as a compliance aid rather than a source of new rules.
The guide applies to any gambling offer requiring online player registration, including competitive betting, online lottery and network gaming tied to a player account. It does not cover activity conducted solely through physical distribution networks that involve no online sign-up.
ANJ describes the guide as supplementary to standards already set out in legislative and regulatory texts, particularly the September 9, 2021 framework for combating fraud and money laundering. Operators retain their contractual freedom, and the guide leaves case-by-case analysis of individual situations to each operator.
Under Article L. 320-4 of the Code de la Sécurité Intérieure, operators are required to contribute to fraud prevention. Companies seeking authorization to offer online gaming or betting must also demonstrate their capacity to meet anti-fraud obligations, per the third paragraph of Article 18 of the May 12, 2010 law governing the sector’s opening to competition.
ANJ developed the guide through consultation with licensed operators and further discussion with the gaming ombudsman.
Five categories of player fraud
The guide sets out a typology of five fraud categories that operators may encounter: 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 are moved between accounts disguised as a poker chip transfer.
ANJ describes this typology as non-exhaustive. The guide also lists several practices operators flagged during consultation — including betting bots, betting syndicates, late bets and repeated account opening and closing for bonus purposes — that the regulator declined to classify as fraud, leaving their treatment to individual operators’ contractual terms.
Evidence requirements precede any action
Before addressing what operators should do once fraud is established, the guide sets a threshold: operators cannot refuse to pay winnings or return an account balance based on suspicion alone.
A player’s failure to respond to an operator’s inquiries may reinforce suspicion but does not by itself constitute proof. To help operators gauge what courts expect, the guide includes a review of case law addressing the evidentiary bar applied in disputes.
For confirmed fraud cases, the guide clarifies actions required under current law or offers recommendations regarding the fraudulent account and its balance, covering scenarios from hacked accounts to falsified bank details.
It closes with recommendations on penalty clauses operators may apply to players found to have committed fraud, referencing legal texts and case law that govern such provisions.
