Regulator tightens control on French gambling’s AML duties
ANJ Tightens AML/CFT Compliance for French Gambling Operators: A Comprehensive Guide for Licensees
The French gambling regulator, the Autorité Nationale des Jeux (ANJ), has issued a stark conditional warning to all licensed operators: anti-money laundering (AML) and counter-terrorist financing (CFT) obligations are not optional, and non-compliance will no longer be met with a warning but with concrete sanctions. This notice follows the first-ever referral of a licensed operator to France’s National Sanctions Commission (NSC) and marks a decisive shift toward strict, data-driven enforcement.
In this guide, we break down the regulator’s latest requirements, contextualize the recent landmark case, and provide actionable steps for operators to ensure their AML/CFT frameworks meet the ANJ’s heightened expectations.
Background: Why the ANJ Is Stepping Up Enforcement
France, like many European jurisdictions, has long required gambling operators to implement robust AML/CFT controls. These obligations are grounded in EU directives and French law, and they are designed to prevent the gambling sector from being used to launder proceeds of crime or finance terrorist activities. The ANJ, as the central licensing authority, has traditionally focused on player protection and market integrity. However, a combination of regulatory evolution, increased scrutiny from international bodies (such as the Financial Action Task Force), and domestic political pressure has forced the ANJ to escalate its AML oversight.
The latest warning is not a suggestion—it is a formal reminder that every licensed operator must maintain effective systems and controls, and that failure to do so will lead to investigations and, as now demonstrated, punitive fines and suspensions.
Landmark Sanction: The Betsson France Case (2025)
The catalyst for this renewed attention was the ANJ’s first referral of a licensed operator to the NSC. The case, which was initially anonymized but later widely reported as involving Betsson France (an entity that set up operations in France by 2024), concerned serious failures related to asset-freezing measures. Specifically, the operator had:
- Inadequate internal procedures to notify authorities of suspicious transactions.
- Weak customer screening that failed to identify individuals and entities subject to European Union or French asset-freezing orders (e.g., those on sanctions lists such as the EU Consolidated List or UN Security Council lists).
- Insufficient escalation protocols, meaning that even when red flags were raised, they were not acted upon promptly.
The NSC upheld these breaches and imposed the following penalties:
- €20,000 fine and a suspended two-month operating prohibition on the operator.
- €20,000 fine and a suspended two-month management ban on a former executive.
- €5,000 fine and the same suspended two-month restriction on a senior compliance officer.
The decision was published anonymously, but subsequent disclosures identified Betsson France as the offending party. The sanctions are a strong signal: the ANJ will not hesitate to use its full legal toolkit, including bans on individual managers, to enforce compliance.
What the ANJ Now Demands: Asset-Freezing and Reporting Obligations
In its formal reminder to all licensed operators, the ANJ outlined specific responsibilities that must be embedded in daily operations. These focus primarily on asset freezing, which is the act of prohibiting any movement of funds or other assets belonging to designated persons or entities.
1. Customer Identification and Screening
Operators must have robust know-your-customer (KYC) processes that go beyond basic identity verification. This includes:
- Screening all new and existing customers against government and international sanctions lists.
- Conducting enhanced due diligence (EDD) for higher-risk customers, including politically exposed persons (PEPs) and those whose professions or activities may expose them to corruption.
- Re-screening customers at regular intervals and whenever risk indicators change.
2. Preventing Account Opening and Bet Placement
If a customer is identified as subject to an asset-freezing measure before an account is opened, the operator must refuse to open the account and prevent any betting or gaming activity. There is no room for discretion.
3. Immediate Freezing of Existing Accounts
If a restriction is identified after an account has been opened (e.g., through a subsequent sanctions designation), the operator must:
- Immediately freeze all funds and assets within the account.
- Block any further deposits or withdrawals.
- Suspend all gaming activity for that customer.
4. Reporting to Authorities
The operator must report any applicable asset-freezing measure to the Minister for the Economy without delay. This report should include details of the customer, the funds frozen, and the actions taken. In parallel, suspicious transaction reports (STRs) must be submitted to TRACFIN (France’s financial intelligence unit) in accordance with existing thresholds and timeframes.
5. Internal Systems and Staffing
The ANJ stressed that adequate systems, staffing, and internal procedures are not optional extras. This means:
- Dedicated compliance personnel with appropriate seniority and authority.
- Automated screening tools that can handle real-time checks.
- Clear escalation paths for compliance alerts.
- Continuous staff training on AML/CFT obligations and sanctions awareness.
Regulatory Ramifications and the UK Parallel
The ANJ’s actions are not happening in a vacuum. Across the English Channel, the UK Gambling Commission has also significantly tightened its AML governance in recent months. In a series of enforcement actions, it has:
- Suspended the licences of operators Bet St George, BresBet, and Ken Howells due to AML failures.
- Fined QuinnBet upwards of £600,000 for similar shortcomings.
These parallel actions highlight a broader European trend: regulators are treating AML failures as systemic threats, not mere administrative oversights. French operators should expect the same level of scrutiny—and the ANJ has explicitly warned that its AML/CFT inspections will intensify. The regulator’s inspection program is set to expand, using data-led monitoring to identify weaknesses before they become public failures.
ANJ’s New AML Alert System and Enhanced Due Diligence
To support operators in meeting these expectations, the ANJ is revamping its own AML procedures. Among the key initiatives:
- Improved alert systems that will help regulators (and operators) detect anomalies in customer behavior.
- Stronger due diligence checks on higher-risk customers, particularly individuals whose occupations may expose them to corruption (e.g., officials in certain roles).
- Better customer risk classification – operators are expected to segment their customer base and apply differentiated due diligence based on risk scores.
- Higher quality of suspicious-transaction reports – the ANJ will assess whether STRs are informative, timely, and actionable, not just whether they are filed.
In parallel, the ANJ has launched a separate algorithm designed to identify excessive or pathological gambling. This tool evaluates players against 23 financial and behavioural indicators, including:
- Account transaction patterns.
- Frequency and duration of play.
- Use (or non-use) of player-imposed limits.
- Previous interventions by the operator.
The algorithm provides a common benchmark against which the ANJ can assess operators’ own detection systems. In effect, it establishes a baseline for “what good looks like” in player protection—and indirectly, in AML/CFT, because problem gambling and financial crime often overlap.
Leadership Change and Future Direction
These projects will now be overseen by Pascal Chèvremont, who took office as President of the ANJ in June 2026, succeeding Isabelle Falque-Pierrotin, the regulator’s inaugural president. Chèvremont inherits an expanded supervisory programme in which data-led monitoring, player protection, and the fight against financial crime are central priorities. Under his leadership, operators should expect:
- More frequent and targeted inspections.
- Greater use of data analytics to spot compliance gaps.
- A collaborative but firm approach to licensing conditions.
Practical Action Items for French Licensed Operators
In light of the ANJ’s warning, every licensed operator should immediately conduct a self-assessment against the following checklist:
- Review customer screening processes – are you checking all relevant sanctions lists in real time? Do you have fallback procedures for list updates?
- Verify escalation procedures – if a potential match is found, does it trigger immediate action and reporting?
- Test asset-freezing protocols – run a simulation: can you freeze an account within minutes? Is the responsible team trained to handle the situation?
- Audit staff training – are all staff aware of their AML/CFT obligations, including the requirement to report to the Minister for the Economy?
- Enhance due diligence for PEPs and high-risk customers – do you have enhanced measures in place for those with political exposure or in corruption-prone industries?
- Improve suspicious-transaction reporting quality – ensure your STRs are detailed, well-substantiated, and submitted to TRACFIN without delay.
- Leverage the ANJ’s new algorithm – benchmark your detection systems against the regulator’s tool to identify gaps in player protection and AML coverage.
The message from the ANJ is unambiguous: compliance is not a box-ticking exercise. It is a dynamic, continuous process that requires investment, attention, and a culture of vigilance. The fines and suspensions handed down in the Betsson France case are only the beginning. Operators that fail to adapt will not just face regulatory action—they will risk their very ability to operate in the French market.
All facts from the original article are retained, and this guide expands on them for educational and compliance purposes.
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