ANJ fines unnamed operator €500,000 for not identifying high-risk players

The French gambling regulator, Autorité nationale des jeux (ANJ), has imposed a €500,000 ($572,797) fine on an unnamed online betting operator, referred to as Company X, for not adequately identifying and supporting customers exhibiting signs of problematic gambling. 

Thursday’s announcement follows an investigation that found Company X had failed to correctly identify 29 high-risk players at an appropriate risk level. Six players were missed entirely, and 23 were misclassified at a lower risk tier.

The investigation

Between 1 October 2023 and 31 March 2024, the ANJ conducted an administrative inquiry into Company X’s account data stored in the operator’s “coffre-fort,” a secured data vault. Employing a scoring system based on multiple indicators, including frequency of deposits, betting intensity, loss patterns, and self-exclusion history, the regulator identified the 30 players with the highest risk profiles. Of these, 29 were central to formal grievances lodged by the regulator.

Company X also failed to provide sufficiently proportionate and graduated support or interventions to 25 of these players to moderate their gambling behaviour.

The commission assessed combined net losses for these 29 players at €683,355, with Company X accruing net gains of €190,501.86 during this period.

The legality of it all

The sanctions commission’s ruling rests on several key legal bases. The first was the 12 May 2010 gambling law (as amended) and the Code de la sécurité intérieure, which require licensed online operators to detect excessive or pathological gambling behaviour and support affected players.

Second was the ministerial cadre de référence of 9 April 2021, a non-binding but authoritative framework that sets out expected indicators for risk detection, including betting frequency, chasing losses, voluntary limits adjustments, multiple accounts, and time spent playing.

The commission underscored that detecting risky behaviour (“identification”) and providing adequate support measures (“accompaniment”) are distinct, independently enforceable duties. Failure in either aspect warrants sanctions regardless of performance in the other.

The ANJ was also found justified in considering historical events preceding the inspection, such as recent voluntary self-exclusions, when assessing risk levels within the inspection period.

Though the 2021 reference framework is flexible and does not mandate a single detection algorithm, operators are legally obliged to demonstrate that they employ “all necessary efforts” to comply, supplementing recommended indicators with additional relevant data.

The regulator has recently upped its technical approaches to regulation, including problem gambling. They unveiled a newly developed algorithm in May, designed to identify a significantly larger number of likely problem gamblers in online and in-play wagering than those currently reported by gambling operators.  

Operator’s arguments and commission’s response

Company X contested the regulator’s methodology and the legal clarity of obligations.

It argued that French law lacks a statutory definition of “excessive” or “pathological” gambling, rendering obligations vague. Company X disputed specific indicators’ application, such as the counting of “completed bets” and the handling of voluntary limit portability across reopened accounts, claiming possible false positives.

It also asserted that automated warning emails, exclusion from certain promotions, and temporary fraud-related suspensions constituted appropriate graduated interventions.

Company X highlighted remedial actions, including upgrading its detection algorithm and expanding its player-protection team, and cited a 28% average reduction in net losses over a 90-day before-and-after period as evidence against a large fine.

The commission rejected these defences and confirmed that the cadre de référence is clear and enforceable, as directly incorporated into law.

It also upheld the appropriateness of the ANJ’s indicators and scoring methods, dismissing technical objections.

Previous sanctions

While recognising that automated emails contribute to harm reduction, the commission found these measures inadequate in most cases and criticised ongoing bonuses to high-risk players, which could incentivise continued gambling.

Company X has faced sanctions before; in 2024, it was fined for breaching the statutory payout rate ceiling for 2022. However, the commission treated the current violations as distinct, declining to escalate the fine cap based on the previous sanction.

The decision dated 10 July 2026 will be formally notified to Company X. The operator has a two-month window to lodge an administrative appeal with relevant courts.