France Fines Online Betting Operator €45,000 Over Asset-Freezing Failures

France’s National Sanctions Commission has imposed a combined €45,000 in financial penalties on an anonymised licensed online betting operator and two individuals following breaches of obligations relating to asset freezing and anti-money laundering and counter-terrorist-financing controls.

The case was referred to the National Sanctions Commission by France’s gambling regulator, the Autorité nationale des jeux (ANJ), following an inspection of the operator. It represents the first time the ANJ has referred a licensed gambling operator to the commission for alleged failures relating to anti-money laundering and terrorist-financing obligations.

The operator was fined €20,000, while a former chief executive was fined a further €20,000 and another individual involved in the relevant compliance process was fined €5,000. The sanctions also included two-month suspensions of online gambling or management activities, but those suspensions were imposed with a stay and therefore do not amount to an immediate two-month shutdown of the operator.

The proceedings concerned an account opened for a person who appeared on France’s national register of persons and entities subject to asset-freezing measures. According to the decision, the customer opened an account in December 2023 and the operator’s systems generated an alert identifying the potential match.

Despite the alert, the account was subsequently confirmed. The operator later argued that an employee had treated the match as a false positive because of similarities in the names involved. The sanctions commission nevertheless concluded that the procedures in place had failed to prevent the account from being opened and maintained despite the relevant asset-freezing designation.

The ANJ identified the issue during a subsequent review comparing information on the national asset-freezing register with archived information held by the operator. The regulator opened an administrative investigation in January 2024, after which the operator conducted an internal review and closed the customer's account.

The sanctions commission distinguished between closing an account and freezing assets. Where a customer is identified as being subject to an asset freeze after an account has already been opened, the appropriate response is to freeze the relevant funds and notify the competent authorities rather than simply terminating the customer relationship.

The commission also found that the operator had failed to provide the required information to the minister responsible for the economy. The notification obligation applied once the operator knew that the customer was subject to the relevant asset-freezing measures.

The ANJ stated that the investigation identified several failures, including deficiencies in the operator’s asset-freezing arrangements, inadequate internal procedures and the failure to inform the minister responsible for the economy.

The sanctions did not establish that the customer had committed money laundering or terrorist financing. The proceedings concerned the operator’s compliance with legal obligations relating to asset freezing and financial-crime controls.

The commission also rejected a separate allegation concerning customer identification requirements. The allegation that the operator had failed to refrain from establishing or continuing a business relationship because it could not adequately verify the customer's identity or obtain the required information was not sufficiently established.

The decision therefore distinguishes between the confirmed failure concerning asset-freezing procedures and the separate customer-identification allegation that was dismissed.

The published decision anonymised the operator and the individuals involved. The sanctions commission explained that the identities were not disclosed in order to avoid disproportionate prejudice to the parties concerned.

Responsibility was assessed according to the roles held by the individuals at the time of the relevant events. The former chief executive was sanctioned in connection with responsibility for implementing the company's financial-crime compliance framework, while another individual was sanctioned based on their role in the relevant decision-making process. Other individuals were not sanctioned where the commission did not establish the required responsibility for the conduct in question.

The case originated with an ANJ inspection conducted as part of its supervision of licensed gambling operators. In July 2025, the ANJ referred the matter to the National Sanctions Commission. The commission subsequently held a hearing on 8 July 2026 before issuing its decision.

France requires gambling operators to maintain measures designed to prevent their services from being used for fraud, money laundering and terrorist financing. Asset-freezing requirements form part of this broader financial-crime control framework.

The case illustrates the importance of distinguishing an automated sanctions or asset-freezing alert from the operational decision that follows it. In this instance, the operator's system generated an alert, but the alert was not converted into the required preventative action.

For online betting operators, an effective asset-freezing framework therefore needs to address the treatment of potential matches during account opening as well as matches involving existing customers. Procedures need to establish who reviews an alert, what information must be considered before a match is dismissed as a false positive, when betting or account activity must be restricted, how funds are frozen and when the competent authorities must be notified.

The distinction between freezing funds and closing an account is also significant. Closing a customer relationship does not necessarily satisfy an asset-freezing obligation because funds held by the operator may remain subject to legal restrictions and reporting requirements.

The case also demonstrates the importance of documented escalation procedures. A potential match that is incorrectly classified as a false positive can result in the continuation of a customer relationship despite an applicable asset-freezing measure. Controls therefore need to ensure that decisions involving potentially designated customers are subject to appropriate review and that the reasons for resolving an alert are recorded.

The ANJ said it intends to intensify its controls over operators' compliance with their financial-crime obligations. Its supervisory framework includes examination of operators' anti-money laundering and counter-terrorist-financing arrangements.

The National Sanctions Commission has authority to impose sanctions on gambling operators, including financial penalties and measures affecting their ability to conduct regulated activities.

The French case does not establish that the operator was involved in a wider money-laundering scheme or that illicit funds passed through the account. The findings concern a specific compliance failure involving an individual subject to an asset-freezing measure and the operator's subsequent handling of the alert.

The decision nevertheless establishes that failure to correctly implement asset-freezing requirements can result in financial penalties and suspended restrictions on gambling activities. It also demonstrates that gambling-sector AML/CFT supervision in France can lead to proceedings before the National Sanctions Commission where deficiencies identified during an ANJ inspection are considered sufficiently serious to warrant referral.

The sanctions therefore concern the operator's compliance systems and the responsibilities of the individuals involved rather than a finding that the betting operator itself participated in money laundering or terrorist financing.

By fLEXI tEAM