ANJ reports improvements in AML compliance efforts

The French National Gaming Authority (Autorité Nationale des Jeux, ANJ) has released its latest assessment of gambling operators’ annual action plans aimed at combating fraud, money laundering (AML), and terrorist financing (CFT). The report, which evaluates the progress made throughout 2024, acknowledges notable strides among licensed operators. However, the regulator has emphasized that critical weaknesses remain and has outlined heightened expectations for the coming year.

This assessment plays a key role in ensuring that the French gambling industry upholds strict compliance with national and European regulations designed to prevent the financial system from being exploited for illicit purposes.

Annual AML/CFT plans as a cornerstone of regulatory oversight

In France, licensed gambling operators are legally required to submit annual action plans detailing their measures for preventing money laundering and terrorist financing. These plans serve as a foundation for dialogue between ANJ and each operator, allowing the regulator to ensure transparency, offer guidance, and demand enhancements where necessary.

The legal foundation for this regulatory process stems from the decree of 9 September 2021, which outlines the responsibilities and obligations of gambling operators in this domain. These include risk identification, internal control frameworks, reporting mechanisms, staff training, and the implementation of technological tools for anomaly detection.

Encouraging signs of progress in 2024

In its review, ANJ highlighted several areas of progress compared to previous years. Operators showed notable improvements in detecting irregular betting behaviors, strengthening their internal resources, and improving the quality of their reporting to TRACFIN, France’s financial intelligence unit responsible for analyzing and combating money laundering and terrorist financing.

Furthermore, the action plans revealed a growing awareness among operators about the risks associated with both physical and digital gambling environments. Several companies pledged to increase their workforce dedicated to compliance, provide more specialized training to staff, and implement more sophisticated alert systems.

These developments reflect a positive trajectory in the overall maturity of the sector’s AML and CFT culture.

Specific shortcomings and 2025 compliance priorities

Despite these encouraging developments, ANJ’s review identified areas where compliance efforts still fall short. These include insufficient detail in risk analyses, underreporting of suspicious activities to TRACFIN, and weaknesses in monitoring exclusive-rights retailers, such as those operating under Française des Jeux (FDJ) and Pari Mutuel Urbain (PMU).

To address these gaps, ANJ has issued concrete recommendations and requirements for 2025. Among the top priorities are:

• Enhancing the precision and relevance of the data provided in AML/CFT reports
• Strengthening oversight mechanisms for third-party networks and retail agents
• Improving the technical sophistication of risk-based detection systems
• Significantly increasing the volume and quality of TRACFIN reports
• Establishing more robust internal governance structures and escalation procedures for suspicious activities

ANJ also reminded operators that submitting comprehensive and well-analyzed reports is not only a regulatory duty but also a key tool in protecting the integrity of the sector.

Greater collaboration with financial authorities

In light of the growing complexity of financial threats and evolving typologies of fraud, ANJ has committed to increasing collaboration with other public authorities. This includes closer cooperation with TRACFIN and other branches of the Ministry of Finance to ensure a harmonized approach to financial crime prevention.

This effort also aligns with broader European initiatives, including the upcoming EU Anti-Money Laundering Authority (AMLA), which aims to improve cross-border enforcement and coordination among member states. ANJ’s strategy reflects this shift toward more centralized and integrated financial crime supervision.

Monitoring and enforcement strategies for 2025

To ensure that operators meet the enhanced expectations for 2025, ANJ plans to implement a more rigorous monitoring framework. This will include:

• Targeted audits of operators' AML/CFT frameworks
• More frequent and structured compliance interviews
• Mandatory updates to action plans throughout the year, depending on observed risk changes
• Detailed follow-ups on previous deficiencies and the corrective measures implemented

These measures underscore ANJ’s shift from advisory oversight to proactive enforcement. Operators that fail to meet their obligations may face administrative sanctions or even license reviews in severe cases.

Risk-based approach as a regulatory foundation

ANJ continues to advocate for a risk-based approach to compliance, in line with international standards such as those issued by the Financial Action Task Force (FATF). This means operators must prioritize resources and controls in proportion to the level of risk associated with their offerings, customer base, transaction types, and distribution models.

For instance, online casino platforms, which are inherently more vulnerable to anonymous transactions and cross-border operations, are expected to maintain stricter onboarding procedures and continuous monitoring systems compared to traditional retail outlets.

Evolving typologies of financial threats

The report also briefly touched on the evolving nature of threats facing the gambling industry. These include:

• Use of gambling platforms to launder proceeds from cybercrime and digital fraud
• Increased use of cryptocurrencies and decentralized platforms that fall outside traditional regulatory scopes
• Sophisticated layering techniques involving multiple betting accounts and intermediaries
• Insider manipulation in sports betting markets

ANJ emphasized that operators must remain agile in responding to these developments and incorporate real-time threat intelligence into their AML/CFT systems.

Training and culture as critical success factors

Beyond systems and reporting tools, ANJ stressed the importance of building a strong internal culture of compliance. Operators are expected to ensure that all relevant personnel receive adequate, ongoing training. This is particularly crucial for frontline staff and those responsible for monitoring transactions, onboarding customers, and reporting suspicious activity.

Several operators, particularly those with international operations, have committed to aligning their training programs with global best practices. This includes simulation exercises, access to anonymized case studies, and scenario-based evaluations.

Looking ahead: a stricter regulatory climate

The gambling industry in France is likely to face increasing regulatory pressure in the coming years. With mounting public scrutiny around responsible gambling, financial crime prevention, and corporate governance, operators cannot afford to view compliance as a box-ticking exercise.

ANJ’s latest report sends a clear message: while progress has been made, the bar is rising, and only those operators that embed AML/CFT into the core of their business strategy will be able to thrive in a tightening regulatory landscape.

Conclusion

The latest review by ANJ underscores both the progress and the persistent challenges facing France’s gambling sector in its efforts to combat money laundering, fraud, and terrorist financing. While many operators have made meaningful improvements in 2024—particularly in areas such as anomaly detection, reporting quality, and resource allocation—the regulator has made it clear that the current level of compliance is not sufficient.

With stricter expectations set for 2025, the onus is now on operators to further strengthen their internal controls, enhance cooperation with financial intelligence bodies such as TRACFIN, and adopt a genuinely risk-based approach to their operations. ANJ’s increased oversight and enforcement efforts will undoubtedly raise the bar, pushing the industry toward a more transparent, secure, and responsible framework.

As financial threats evolve and public scrutiny of the gambling sector intensifies, compliance can no longer be treated as a formality. It must be integrated into the very structure of corporate governance and operational strategy. For operators, this is not merely about avoiding penalties—it is about preserving trust, protecting the integrity of their platforms, and contributing to the broader fight against financial crime.

FAQs

What is ANJ?
ANJ stands for Autorité Nationale des Jeux, the French National Gaming Authority responsible for regulating gambling in France.

Why must gambling operators submit annual AML plans in France?
French law requires gambling operators to submit annual action plans to demonstrate how they combat money laundering and terrorist financing.

What is TRACFIN?
TRACFIN is France's financial intelligence unit that monitors suspicious financial activities and supports the fight against money laundering and terrorist financing.

How did French gambling operators perform in 2024?
Operators showed improvement in fraud detection, reporting quality, and internal resources, but ANJ noted several areas still needing enhancement.

What are the 2025 priorities for gambling operators according to ANJ?
Key priorities include better data quality, oversight of third-party agents, more sophisticated alert systems, and increased TRACFIN reporting.

How is ANJ planning to enforce compliance?
ANJ will implement more audits, structured interviews, and enforce corrective actions based on 2024’s deficiencies.

What are some new threats in gambling-related financial crime?
New threats include crypto-based laundering, cybercrime funds entering betting platforms, and complex account layering tactics.

Why is staff training important in AML/CFT compliance?
Trained staff are essential for detecting suspicious behavior, ensuring correct reporting, and maintaining overall compliance culture.

How does the risk-based approach work in gambling compliance?
Operators allocate more resources and stronger controls to higher-risk activities like online gaming or high-volume bettors.

What could happen to operators that fail to comply?
Non-compliant operators risk sanctions, license suspensions, or public warnings, depending on the severity of the breaches.