French ANJ Sets New Limits on Fraud Suspicions: Evidence Over Assumptions

The French gambling regulator, Autorité Nationale des Jeux (ANJ), released a landmark document on August 31, 2026, redefining the rules for online gambling operators in the fight against fraud. Developed in close consultation with licensed operators and the gambling ombudsman, the guide does not impose new laws but specifies how existing anti-fraud and anti-money laundering regulations should be applied in practice. This initiative follows a phase of consultations where it became clear that the line between a house's legitimate defense and the unfair disadvantage of players is often blurred.

The new ANJ guidance focuses on identifying and responding to fraudulent activities without infringing on the rights of honest customers. A particularly sensitive point is the authority's clear instruction that operators may no longer act on mere suspicion. Anyone wishing to freeze winnings or block accounts must provide tangible evidence. The document covers a wide range of issues, from payment fraud and game manipulation to so-called money dumping, where funds are moved between accounts under the guise of poker chip transfers.

Numbers and facts

In its guide, the ANJ distinguishes between five main categories of fraud: civil identity fraud, payment method fraud, abusive chargebacks, gambling fraud such as poker collusion, and money dumping. Interestingly, the authority explicitly declined to classify certain practices frequently reported by operators as fraud. These include the use of betting bots, betting syndicates, late bets, and repeated account opening and closing for bonus purposes. Operators must decide how to handle these via their own Terms and Conditions (T&Cs).

A central aspect of the new directive is the burden of proof. The ANJ emphasizes that technical data such as IP addresses, device logs, connection times, and similarities in betting patterns must be collected to characterize fraud. A player's silence in response to an operator's inquiries is not sufficient as sole proof.

“Characterizing fraud requires the collection of probative evidence, and the operator cannot refuse to pay a win or return part or all of an account balance on the basis of mere suspicions, without undermining the binding force of the gambling contract.” - ANJ Representative, French National Gambling Authority

Background

The legal basis for these guidelines is found in Article L. 320-4 of the Code de la Sécurité Intérieure and the framework of September 9, 2021, for combating fraud and money laundering. The ANJ is responding to a growing number of disputes where players complained about arbitrarily withheld balances. While the guide allows operators contractual freedom, it simultaneously provides a framework aligned with current French case law. In cases of confirmed fraud, the authority recommends closing the account, with the treatment of the remaining balance requiring individual assessment based on the type of fraud.

Why it matters for German players

For German players active with operators licensed by the Joint Gambling Authority of the States (GGL), this development in France is an important signal. While the ANJ guidelines apply directly only to the French market, there is often an alignment of consumer protection standards within the EU. In Germany, the State Treaty on Gambling 2021 (GlüStV 2021) already strictly regulates how accounts are managed. Systems like LUGAS and OASIS closely monitor identities and limits. Withholding winnings without evidence is legally tenuous in Germany as well. German players benefit from regulatory authorities increasingly demanding precise technical evidence before an operator can resort to sanctions.

What it means for GGL-licensed casinos

German casinos on the GGL whitelist are already required to maintain strict KYC (Know Your Customer) systems. The French recommendations for tightening technical standards and reviewing account matching could serve as a blueprint for future German requirements. Operators must ensure their T&Cs clearly define what constitutes abuse to act with legal certainty. Especially with the German stake limit of 1 Euro per spin and the monthly deposit limit of 1,000 Euros, clean documentation of all transactions is essential to provide the necessary chain of evidence in case of suspected fraud.