France’s ANJ Tells Operators: Suspicion Is Not Enough to Withhold Player Funds

Key Points

• ANJ published a practical fraud guide on 31 August 2026, clarifying evidence standards without creating new legal duties.
• Operators cannot withhold winnings or account balances on suspicion alone; courts have already ruled against them when proof was insufficient.
• France’s gambling mediator logged 1,856 dispute requests in 2025, a 20% year-on-year rise, with 42.4% tied to account management.

French Courts Were Already Deciding This

Two court cases. Two drastically different outcomes. And one regulator who was definitely aware of both. The Paris Judicial Court ruled in July 2025 that there was not enough evidence of fraud for Winamax to invalidate five wagers, forcing the operator to pay out more than €402,000 on those wagers, as well as the balance of the player’s account which totalled €218.68. The operator claimed that the player used broadcast delays to place bets on known outcomes, but the court ruled the evidence insufficient. Later, Betclic found itself under similar scrutiny in the Paris Court of Appeal, with the ruling coming out to be totally different. This was due to the fact that, among other things, a shared IP address and terminal as well as 35 bets on identical dates, with the majority of them being placed in less than five minutes, were mentioned, and the fact that a judicial officer confirmed the authenticity of the documents without alterations made by Betclic. Account suspension was maintained, but Betclic was also obliged to refund the player €32,785.30. One and the same issue, the same legal system – two opposite verdicts. The ANJ, the gambling regulator in France, noticed.

What the Guide Actually Says?

Published on 31 August 2026 following consultations with licensed operators and the gaming ombudsman, the ANJ’s new fraud guide sets out a practical framework for how operators should identify, investigate, and respond to player fraud. It does not introduce new legal obligations. What it does instead is something arguably more consequential: it tells operators exactly what French courts expect to see before any action affecting a player’s money is taken.

The central statement in the guide carries real legal force. The ANJ states that characterising fraud requires the collection of probative evidence, and that an 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. That is not regulatory caution. That is a contractual argument French judges have already used against operators in live cases. The guide applies to all gambling products involving online player registration, covering online betting, lottery products, and retail networks requiring a player account.

Six Fraud Types, and the Evidence Each One Demands

The ANJ identifies six categories of player fraud that licensed operators most commonly encounter. These are identity fraud, payment fraud, abusive chargebacks, in-game cheating such as poker collusion and bot use, money-dumping between accounts, and sporting event manipulation. The regulator is clear that this list is not exhaustive; operators retain discretion over practices including betting syndicates, late bets, and repeated account cycling for bonus purposes, treating those under their own contractual terms rather than as defined fraud.

For each fraud type, the guide maps applicable legal provisions alongside recommended operational responses. In identity fraud cases, operators are advised to close accounts once fraud is established and to hold balances in reserve where bank account ownership cannot be confirmed. For account takeovers, the guide pushes technical measures upfront, specifically two-factor authentication for withdrawals and changes to banking details. On poker collusion and bot use, courts have already validated the redistribution of illegitimate winnings to affected players, but only where the operator’s decision was backed by strong data, a point the guide underlines deliberately.

What the ANJ calls “converging indicators,” or faisceaux d’indices in French law, form the evidentiary backbone the guide points operators toward. These include IP addresses, device logs, and connection timings. The guide is also explicit that a player’s silence in response to operator enquiries may deepen suspicion, but it does not constitute proof on its own.

A Mediation System Under Pressure

The timing of this guide is not coincidental. France’s gambling mediator received 1,856 dispute requests in 2025, a 20% increase on the year before, with sports betting accounting for 91.5% of admissible cases. Among those, 42.4% involved account management disputes, including blocked accounts and withdrawal difficulties. Cases linked to suspected or proven fraud rose considerably over that period, and with the Winamax ruling still fresh in legal memory, operators now carry a financial incentive to get evidentiary standards right before acting, not after a legal challenge lands.

The pressure is not limited to France either. On 12 August 2026, Britain’s Gambling Commission reminded remote operators that identity checks should be completed as early as practicable, warning that waiting until a withdrawal request before following up outstanding queries is not acceptable practice. Two regulators, in two jurisdictions, arriving at the same conclusion from different directions: operators need to verify sooner and document better.

ANJ’s Wider Enforcement Pattern in 2026

The guide against fraud is not standing in isolation; it comes as part of a continuous regulatory assault from the ANJ which has become more aggressive throughout 2026. In July, the gambling regulator penalised an online betting firm identified as Company X with a €500,000 fine after establishing that the firm had neglected to recognise 29 high-risk gamblers at a proper risk category, failing to recognise six and identifying 23 gamblers at a lesser risk category. The inspection involved activities in the accounts of the 29 gamblers within the period of October 2023 to March 2024.

Company X challenged the results, claiming that the concept of “excessive” or “pathological” gambling was not defined in French legislation, rendering the duties ambiguous. The sanctions committee did not accept such an argument and explicitly acknowledged that the ministerial reference framework of April 2021 was applicable. In the early days of 2026, ANJ conducted a national campaign during the World Cup following a Toluna-Harris poll indicating that 41% of adults in France planning to watch the event also planned to bet in real money. The president of ANJ, Isabelle Falque-Pierrotin, said explicitly: “We enter a risky phase with several warning signs for the regulator: more matches, and thus more opportunities for advertising and betting and, at the same time, we notice an increase in the number of problem gamblers.”

Across fines, awareness campaigns, and now a fraud evidence guide, the ANJ is building a regulatory posture that leaves operators very little room for ambiguity about what is expected.

Expert Analysis: The Guide Is Useful – The Problem It Cannot Fix Is Not

We think the ANJ has produced something genuinely valuable here, and that is precisely why the gap it leaves behind deserves scrutiny. The guide essentially asks operators to build court-ready evidence files from the moment suspicion arises, before any account action is taken. That is a reasonable standard, grounded in real case law. The Winamax ruling made clear that courts will not accept instinct as evidence, even when the operator may have been factually right about the fraud.

What the guide cannot resolve, and what we believe nobody in this debate is saying loudly enough, is the speed imbalance at the heart of fraud detection. Betting bots, coordinated collusion rings, and money-dumping operations can execute across multiple accounts in minutes. Building the kind of convergent evidence portfolio that French courts require, with verified IP data, device logs, timestamped connection records, and judicial officer confirmation, takes considerably longer. ANJ’s own April 2026 review of operator anti-fraud action plans acknowledged that alert engineering across the sector still needs improvement, meaning the real-time detection infrastructure required to catch fraud fast enough to act on it remains a work in progress across the industry.

That creates a position operators cannot easily escape. Act on strong suspicion without full evidence, and a French court may order repayment of hundreds of thousands of euros. Wait for bulletproof proof, and the funds may already be gone. The ANJ’s guide draws the legal line with precision. What it does not do is close the technical gap that makes standing on the right side of that line genuinely difficult. Until the regulator addresses detection infrastructure with the same rigour it applies to evidence standards, operators are being asked to meet a courtroom standard with tools that are not yet fast enough to match it.