ANJ fraud guide reminds operators that suspicion cannot justify withholding balances

By jili tutorial · September 3, 2026

ANJ Fraud Guide: Why Suspicion Alone Cannot Justify Withholding Player Balances

The French gambling regulator, the Autorité nationale des jeux (ANJ), has released a comprehensive guide on tackling player fraud. The soft-law document outlines five categories of fraudulent behavior, caps re-registration bans at six years, and reviews eight court rulings to clarify what counts as admissible evidence. A recurring question for operators is: what happens to a player’s account and balance when fraud is suspected? The ANJ’s answer is clear — suspicion is not enough.

What the ANJ Guide Covers

Published on 31 August 2026, the guide was developed in consultation with licensed operators and further discussions with the gaming ombudsman. The ANJ describes it as a soft-law instrument, meaning it creates no new legal obligations and leaves operators’ contractual freedom intact. It applies only to gambling offers that require online player registration and deals exclusively with fraud committed by players. It does not apply where money laundering or terrorist financing is also suspected.

A Soft‑Law Tool, Not a New Rulebook

The guide serves as a reference document rather than a binding set of rules. Operators retain the ability to manage their contracts, but the ANJ provides clear expectations on evidence and procedure.

Five Categories of Player Fraud

The typology, which the ANJ stresses is not exhaustive, covers the following:

Identity fraud
Payment-method fraud
Abusive bank repudiation
Gambling fraud
Money dumping

Identity fraud is the most detailed category, with six sub‑types: forged documents, false registration details, identity theft (including account hacking), account sharing, multiple accounts, and attempts to bypass identity checks.

Notably, the guide deliberately excludes bots, concerted betting in sports and horse‑race betting, late bets, and the repeated opening and closing of accounts to collect welcome bonuses. Operators remain free to address those behaviors contractually. However, poker bots and poker collusion are included within the typology.

What Counts as Proof of Fraud?

The guide reiterates the position from the 2021 reference framework for combating fraud, money laundering, and terrorist financing: establishing fraud requires probative evidence. An operator cannot refuse to pay winnings or withhold part or all of a balance based on mere suspicion, as that would undermine the binding force of the gambling contract.

Operators do not need to file a criminal complaint or take legal action against a player to establish fraud. However, where doubts remain unresolved, the ANJ is explicit:

“While a player’s silence in response to operators’ requests may reinforce their doubt, it does not in itself constitute probative evidence allowing fraud to be established.”

Similarly, a connection from the same device by related individuals does not, on its own, prove account sharing. An annex to the guide reviews eight court decisions from April 2024 to February 2026, showing where judges accepted an operator’s evidence and where they did not.

Closure, Balances, and Penalty Clauses

When sufficient evidence is gathered, the ANJ recommends closing all accounts tainted by fraud. In multiple‑account cases where fraudulent intent is proven, this includes any legitimate account opened under the player’s real identity.

Players whose accounts are closed for established fraud cannot open a new account with that operator for a period set on a case‑by‑case basis, capped at six years from closure.

Treatment of the Balance

How the remaining balance is handled depends on the type of fraud:

Identity fraud: If the operator cannot verify that the payment account belongs to the player, the law requires the money to be held in reserve rather than paid out.
Poker fraud: The ANJ expects operators to state clearly in their terms that they will fairly distribute the winnings taken by the fraudster among the other players in that game or tournament. Any remaining balance is returned to the holder before the account is closed.
Sports manipulation: Bets on a match where manipulation has been proven are cancelled.

Penalty Clauses

Operators may charge a player a penalty for breaching the contract. However, the guide warns that under French consumer law, a penalty is presumed unfair if it is clearly out of proportion to the harm caused. An unfair term is treated as if it were never written. Where the penalty is set as a percentage of the balance, stake, or deposit, the ANJ requires a cash ceiling to be included.