France's Regulator Now Expects Operators to Prove Fraud Before They Close an Account.

The French regulator’s new fraud guide turns suspicion into an evidence-file question and separates the power to end a customer relationship from the power to retain the money left behind.

Publisher: Autorité nationale des jeux (ANJ)

Publication date: 31 August 2026

Instrument: non-binding soft-law guide

Scope: suspected fraud involving online player accounts

Existing framework referenced: ministerial anti-fraud and AML/CFT framework of 9 September 2021

Official notice: https://anj.fr/lutte-contre-la-fraude-par-les-operateurs-de-jeux-dargent-et-de-hasard-un-guide-pour-mieux-traiter

France’s gambling regulator has put a clearer sequence around a recurring operator decision: investigate, assemble probative evidence, characterize the fraud, and only then choose what happens to the player account and its balance. Suspicion alone is not the evidentiary destination.

The legal caveat is essential. This is soft law and non-binding guidance, not new legislation. The ANJ says the guide creates no new obligations and does not displace operators’ contractual freedom. It is designed to help operators comply with rules already in force and to state recommendations and good practices. Calling it a newly binding fraud law would overstate what was published.

The guide still matters as a regulatory benchmark. The ANJ says it answers recurring operator questions, follows consultation with licensees and the gambling mediator, and reviews case law to show the proof judges expect in disputes.

The mechanism begins before closure

The guide’s core demand is evidence capable of proving the alleged conduct, not a label added after a withdrawal request. The ANJ establishes a non-exhaustive typology rather than one universal fraud test. iGamingBusiness’s account of the guide identifies identity fraud, payment fraud and abusive chargebacks, game-related cheating, money dumping and manipulation connected with sporting events among the situations addressed.

The evidence must fit the theory. Connection records, devices, timing, transactions and account activity may become converging indicators when assessed together. A shared connection may support an inquiry, but a raw anomaly is a lead—not automatic proof of dishonest intent. That insistence on verifiable support rather than operator assertion echoes what provably fair means.

The resulting file should preserve the underlying data, its provenance, the links between indicators and accounts, and the reasoning supporting the alleged fraud so outsiders can assess it.

Closing the account and keeping the balance are different decisions

Once sufficiently probative evidence establishes fraud, the ANJ recommends closing the account or accounts affected. In a deliberate multiple-account case, the recommendation can extend to all of that player’s accounts, including an account opened under the player’s genuine identity. The rationale is that proven fraudulent conduct may justify ending the contractual relationship.

Money requires a separate analysis. The fact that closure is justified does not automatically prove that every euro in the account is attributable to fraud or may be withheld. The iGaming and LCB report the regulator’s position plainly: an operator cannot refuse to pay winnings or return all or part of a balance on mere suspicion without undermining the binding force of the gambling contract.

Identity fraud illustrates the split. Where the operator cannot establish who owns the destination bank account, the guide says the affected balance may have to remain in reserve rather than be transferred. In a multiple-account case with fraudulent identity, balances attached to the identity-fraud accounts are reserved. But the ANJ recommends returning the balance of an identifiable account opened without a fraudulent maneuver under the player’s true identity. If the operator cannot establish who owns that ostensibly legitimate account, the guide says its balance is also reserved because ownership remains uncertain.

This is why “the operator can close the account” is not an answer to “the operator can keep the balance.” One asks whether the relationship may end; the other asks what legal and evidentiary basis applies to particular funds. Terms and conditions can organize procedures, but the ANJ’s position does not let a broad fraud clause substitute for proof.

What the guide changes in practice

For operators, the durable task is to build a reviewable file while the relevant data are available: define the suspected conduct, collect corroborating records, assess alternative explanations, preserve provenance and document the separate account and balance decisions. Customer notices should communicate the legitimate reason for closure; the ANJ’s public account-closure guidance already says an operator must give the reason and available routes to contest it.

For players contesting a withheld balance, the guide does not guarantee payment and does not decide an individual dispute. It sharpens the question to put to the operator: what probative evidence establishes the fraud, and what separately justifies retaining these funds? The answer can differ by fraud type and by account. Ultimately, the ANJ says, the guide clarifies current law and recommendations; a competent court remains the body that resolves a dispute when other routes fail. Two days later a Brazilian Senate committee took the opposite approach to the same industry, moving on what a licence permits an operator to advertise through a substitute that is not yet law.

Also: In July, the ANJ’s sanctions commission fined an unnamed licensed online operator for failures to identify and support players showing excessive or pathological gambling risk; the regulator said the decision could be appealed to the Conseil d’État.

Sources:

The mechanism begins before closure

Closing the account and keeping the balance are different decisions

What the guide changes in practice

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