ANJ Fines Operator €500,000 Over Problem Gambling Player Identification Failures

The French gambling supervisory authority, Autorité nationale des jeux (ANJ), has imposed a substantial fine of €500,000 on an anonymous online betting operator, referred to internally as "Company X." The reason: the operator failed to adequately identify and support players exhibiting problematic gambling behavior. This sends a clear signal from the ANJ that it takes its player protection guidelines seriously.

The investigation revealed serious deficiencies. A total of 29 high-risk players were not correctly identified or were misclassified by the company. Six players were missed entirely, while 23 were placed in a lower risk category than their gambling habits warranted. The supervisory authority demonstrates how closely it monitors compliance with regulations.

Numbers and facts

The ANJ conducted its administrative investigation between October 1, 2023, and March 31, 2024. It utilized the operator's account data, stored in a secure data vault, the so-called "coffre-fort." A complex scoring system, based on criteria such as deposit frequency, betting intensity, loss patterns, and self-exclusion history, helped identify the 30 players with the highest risk profiles.

Of these 30 players, 29 were the subject of formal complaints from the regulatory authority. Company X also failed to demonstrate sufficiently proportionate and graduated support measures for 25 of these players to moderate their gambling behavior. The resulting net losses for these 29 players amounted to a total of €683,355. Company X accrued net gains of €190,501.86 during this period. The ANJ's Sanctions Committee met on June 30 to review the matter, applying seven indicators to assess the appropriateness of a penalty, including deposit frequency and the use of self-exclusion tools.

Background

The Sanctions Commission's decision is based on several legal grounds. These include the gambling law of May 12, 2010 (as amended) and the Code de la sécurité intérieure. These laws oblige licensed online operators to detect excessive or pathological gambling behavior and support affected players. Another important reference point is the ministerial reference framework of April 9, 2021. This non-binding but authoritative framework sets out expected indicators for risk detection, including betting frequency, chasing losses, voluntary limit adjustments, multiple accounts, and time spent playing.

The commission emphasized that detecting risky behavior ("identification") and providing adequate support measures ("accompaniment") are two distinct, independently enforceable duties. A failure in one of these areas justifies sanctions, regardless of performance in the other. The ANJ was also entitled to consider past events, such as recent voluntary self-exclusions, when assessing risk levels within the inspection period.

Company X argued that French law lacked a statutory definition of "excessive" or "pathological" gambling, rendering the obligations vague. The operator disputed the application of specific indicators, claiming that automated warning emails, exclusion from certain promotions, and temporary fraud-related suspensions constituted appropriate graduated interventions. The company also highlighted improvements, such as upgrading its detection algorithm and expanding its player protection team. It cited an average 28% reduction in net losses as evidence against a large fine. These arguments were rejected by the commission.

"Some players were not identified as posing a risk, while others were classified as having an insufficient risk level based on their gambling habits." - ANJ Sanctions Commission, Press Release

Why it matters for German players

This case in France underscores the growing importance of player protection in Europe. In Germany as well, regulatory authorities are very active. The State Treaty on Gambling 2021 (GlüStV 2021) introduced strict rules for online gambling to protect players from the dangers of gambling addiction. German online casinos on the whitelist of the Joint Gambling Authority of the Federal States (GGL) must strictly adhere to these regulations. These include a stake limit of €1 per spin on slot machines and a monthly deposit limit of €1,000, which is tracked via the central monitoring system LUGAS.

The GGL, comparable to the ANJ in France, monitors compliance with these rules. It can take tough action in case of violations. Players in German GGL-licensed casinos benefit from these extensive protection measures. They receive greater security and transparency than in casinos that, for example, only hold an MGA or Curacao license. These international licenses often do not offer the same level of player protection and transparency, as they are not subject to German regulations. For German players, this means they are significantly better off in GGL casinos, as the authority ensures continuous monitoring of player protection measures.

What it means for GGL-licensed casinos

For online casinos in Germany under the control of the GGL, the ANJ's ruling is a clear warning. The GGL also expects operators to implement a robust system for identifying and assisting high-risk players. Simple monitoring is not enough. Graduated and effective intervention measures must also be taken. Should GGL casinos exhibit similar deficiencies to the French Company X, they could also face severe penalties. This is important to strengthen player trust in the regulated German market and to maintain high standards of player protection.