France’s gambling regulator has drawn a sharper line between fraud suspicion and proof. The Autorité nationale des jeux (ANJ) says operators cannot refuse to pay winnings or return an account balance merely because activity looks unusual. Controls must identify risk quickly, but decisions affecting customer funds need evidence capable of withstanding contractual, regulatory and judicial scrutiny.
Suspicion alone does not justify withholding winnings or an account balance.
Operators need documented and probative evidence before treating fraud as established.
KYC, payment ownership and account-linking checks should begin before withdrawal.
Account closure does not automatically permit an operator to retain all remaining funds.
The guide is soft law and does not replace legislation, contracts or court decisions.
ANJ published its official anti-fraud guide on 31 August 2026 following consultation with licensed operators and the Gambling Mediator. It provides a practical framework for handling identity fraud, payment fraud, abusive chargebacks, multiple accounts, game-related manipulation and money dumping.
In translation, ANJ’s central warning is unequivocal. “The operator cannot refuse to pay a win or return part or all of an account balance on the basis of mere suspicions.” Automated alerts, behavioural anomalies and unusual transaction patterns can initiate an investigation, but they cannot replace probative evidence when customer funds are withheld.
The guide was formally adopted under Decision No. 2026-131. However, it remains a soft-law instrument rather than a new binding regulation or court judgment. The appropriate response must therefore reflect the type of fraud, the available evidence and the contractual or legal rules governing the account and its remaining balance.
This guidance complements the ANJ’s 2026 AML and anti-fraud action plans, while focusing more specifically on the evidence operators need before closing accounts, withholding withdrawals or retaining funds.
Identity and payment checks cannot be treated as withdrawal-stage obstacles. Operators should verify personal details, payment ownership and destination bank accounts early, then reassess them when risk indicators change.
Device reuse, shared IP addresses, matching payment instruments and similar betting patterns can support an investigation, particularly in coordinated multi-account cases. None should be treated as conclusive in isolation. Shared networks and legitimate device changes can produce false positives.
This evidence-led approach complements France’s wider 2026 regulatory framework, which places stronger emphasis on real-time monitoring, financial integrity and auditable player-protection controls.
Where fraud is sufficiently established, ANJ generally recommends closing the affected account. Deliberate multiple-account fraud may justify closing every account controlled by the same player, including one opened under the player’s genuine identity.
The balance requires a separate analysis. If identity fraud prevents an operator from confirming that the receiving bank account belongs to the player, French rules may require funds to be placed in reserve. In other cases, money not generated by or connected to the fraudulent conduct may need to be returned.
Operators should therefore avoid a single “fraud confirmed” outcome that automatically confiscates deposits, legitimate winnings and residual funds. Chargebacks also require precise reconciliation. Teams must distinguish a disputed payment from unrelated deposits and establish which bets or winnings were funded by the reversed transaction.
A defensible case file should combine verified identity records, device and IP history, payment ownership, account connections, bet timing, chargeback documentation and investigator reasoning. Data exports should preserve timestamps and an auditable chain of custody.
Automated risk scoring can prioritise reviews, as demonstrated by the ANJ’s data-led player monitoring, but human review remains essential before funds are withheld. Operators also need approval thresholds, documented reason codes and escalation routes for high-value cases.
For money dumping or coordinated betting, the file should show the relationship between accounts and explain why the activity lacks an ordinary economic rationale. A cluster of similarities is useful evidence, but the conclusion must remain proportionate to the complete record.
The gambling mediator’s 2025 activity report recorded 1,856 requests, up 20% year on year. Sports betting represented 91.5% of admissible requests, while account blocking, closure and withdrawal difficulties featured prominently. The mediator also reported a considerable increase in cases involving suspected or established fraud.
For B2C operators, the commercial risk is clear. Weak detection can expose the platform to fraud, while unsupported withholding can trigger complaints, litigation and reputational damage. ANJ’s guide makes evidence quality the control point connecting KYC, investigations, withdrawals and account closure.
