The French National Sanctions Committee (CNS) has fined a French-licensed online sports betting operator and two senior executives after finding breaches of European Union and French asset-freezing rules designed to combat money laundering and terrorist financing.
The operator, identified as GU in the decision, received a two-month suspension from operating online betting services and a €20,000 fine. Monsieur AB, its former CEO and head of the parent company providing staff, was given a two-month ban on managing activities in France’s online betting sector and fined €20,000.
Madame BG, GU’s compliance officer, received the same two-month management ban and a €5,000 fine. No sanctions were imposed on the operator’s legal officer, owner or major shareholder.
The case was referred to the CNS by ANJ last year and upheld in July. ANJ published the decision this week. Individual identities were anonymised in the ruling to avoid disproportionate prejudice under procedural rules.
Account opened despite alerts
The case concerned an account opened on 3 December 2023 for a player listed on France’s national register of people subject to an asset-freezing order. GU’s automated systems generated alerts that day, but the operator did not confirm the account until 14 December, 11 days later.
ANJ notified GU and opened an administrative investigation on 3 January 2024. GU closed the account the following day.
The CNS identified two main failings. First, it found that GU did not have effective systems and procedures to ensure that asset-freezing requirements were applied promptly. The account was opened despite the system alerts, contrary to articles L.562-4-1 and R.562-1 of the French monetary and financial code.
The committee characterised the requirement as an “obligation of result”, meaning operators must ensure that prohibited accounts are not created.
Second, GU failed to notify the minister responsible for the economy about the asset-freezing incident and related transactions. No notification was made on 3 December, when the operator attributed the alert to an alleged human error and false positive, or on 4 January, after the account had been closed and the uncertainty should have been resolved.
The CNS rejected a separate allegation involving the acceptance or execution of transactions without verified identity or purpose, citing insufficient evidence.
Compliance expectations
French online gambling operators face anti-money laundering and counter-terrorist financing requirements under the monetary and financial code, including articles L.561-1 et seq, as well as the asset-freezing regime in articles L.562-4 et seq.
Earlier this year, ANJ issued a practical guide covering player fraud identification, documentation and response. The guide did not create new legal obligations, but clarified expectations under existing anti-fraud and anti-money laundering rules, including stronger terms and conditions, better evidence retention and higher technical standards.
