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Compliance Updates

The ANJ publishes its 2024/2026 strategic plan aimed at drastically reducing the proportion of excessive gamblers



The ANJ publishes its 2024/2026 strategic plan aimed at drastically reducing the proportion of excessive gamblers
Reading Time: 3 minutes


Three years after its establishment and the introduction of the new gambling regulation, the ANJ is presenting its strategic plan for 2024-2026. The reduction of excessive gambling and the social damages it causes, as well as the protection of minors, are at the heart of its actions. To achieve this ambitious objective, which reflects a problem that is no longer individual but social, the ANJ is calling on all economic and institutional players concerned to work alongside it.

The first cycle of regulation under the aegis of the French Gambling Authority (ANJ) ended in 2023 with the observation that the gambling market was booming, with revenues of more than €13 billion, representing an increase of more than 50% since the opening of the market in 2011. Over the years, gambling has become a mainstream consumer product for people of all ages and from all walks of life: more than half of all French people now gamble, spending more than €55 billion each year. Gambling is at the heart of our societies, and this phenomenon can be observed in every European country.

However, gambling is not a product like any other, and it is the risks inherent in this activity that have justified the government’s implementation of a restrictive regulatory policy, which translates into a legal objective of limiting and supervising the supply and consumption of gambling.  In 2019, the public authorities wanted to strengthen player protection and the ANJ was created with this objective in mind.

Although gambling operators have made significant progress in this area over the past three years, problem gambling still plays too large a role in the gambling market. In 2019, the Gambling Observatory estimated the number of at-risk gamblers at 1.4 million, including almost 400,000 at pathological level. In total, problem gambling accounts for more than 38% of the sector’s turnover and excessive gambling alone for 21%. These figures, which are due to be updated shortly, illustrate the reality of a social problem, particularly for young people, with collateral damage in the gambler’s in the gambler’s immediate environment: excessive debt, family problems, difficulties at school, etc.

In this context, the ANJ has been working with all stakeholders to define the new regulatory guidelines for the period 2024-2026. These place the protection of minors and the reduction of excessive gambling and the social damage it causes at the centre of the regulator’s activities, like a common thread that inspires all its actions.

The ANJ’s new roadmap is based on three fundamental pillars:

  • The first of these pillars, which reflects the public health implications of regulation, aims to drastically reduce the proportion and number of excessive gamblers in the gambling market. This key objective for the ANJ will require major efforts on the part of operators. It cannot be achieved without a coherent and balanced regulatory policy aimed at consolidating the French gambling market model.
  • At the same time, this requires the ANJ to continue its efforts to preserve the transparency and integrity of the sector, with the fight against illegal gambling at the forefront (second pillar), and to strengthen the economic dimension of regulation in order to gain a better understanding of market balances and provide solutions to the changes it is facing today (third pillar).

Finally, the strategic plan is based on three foundations that are the conditions for the success of its ambition: to make scientific knowledge of the market and gambling practices the compass of regulation; to embody, at national and European level, regulation based on dialogue and cooperation to drive the repositioning of the market; and finally, to position the ANJ as a laboratory for bold, effective and exemplary public action.

This is a critical time for the French gambling market: it can both destabilise and strengthen the French model.  This strategic plan should help to strengthen the French regulatory model as an acceptable compromise between openness and protection.

Isabelle FALQUE-PIERROTIN, President of the ANJ, said: “After three years in office, we now believe that the regulation of gambling must take a turn that involves the market gradually moving towards a less intensive model. This voluntary target to reduce the number of excessive gamblers and to strengthen the protection of minors will be monitored over a period of 3 years and adjusted in line with monitoring indicators and prevalence studies. It can only be achieved if all the players join forces alongside the regulator to move the goalposts: gambling operators, public authorities, institutions, associations, etc. “


Link to the strategic plan


VGCCC Fines BlueBet AU$50,000 for Gambling Advertising Breaches



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BlueBet has been fined AU$50,000 by the Victorian Gambling and Casino Control Commission (VGCCC) for breaching gambling advertising regulations.

The company was found guilty of 43 charges related to displaying gambling advertisements on or above public roads, contravening the Gambling Regulation Act 2003.

The charges stemmed from an investigation initiated by VGCCC, following a complaint from a member of the public. The breaches occurred over a two-week period in August and September 2022, with BlueBet’s gambling advertisements appearing on digital billboards at various locations, including Point Cook, Laverton, Rockbank and Ravenhall.

Magistrate Greg Thomas, overseeing the case, expressed scepticism about BlueBet’s defence that it was unaware of the breaches, given the strategic placement of the billboards to target males aged 15-54 years old. While no conviction was recorded, Magistrate Thomas noted the high degree of negligence exhibited by BlueBet.

VGCCC CEO Annette Kimmitt AM said: “Gambling advertising has no place on public roads where it is readily visible to children and other vulnerable groups. These places are especially difficult to avoid as part of day-to-day activities. This decision sends a clear message to wagering providers that flout these protections for our community.”

Although Magistrate Thomas considered imposing a higher fine and recording a conviction, he took into account BlueBet’s guilty plea, cooperation with VGCCC and measures taken to prevent future breaches. BlueBet has implemented changes to prevent similar incidents and has cooperated with VGCCC throughout the process.

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Compliance Updates

MGA: Updated Non-Profit Tombola and Lottery Application Requirements



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The Malta Gaming Authority has published updated documents outlining the application process and requirements. This includes the revised list of documents required as enclosures with the application for the Non-Profit Tombola, as well as for the Non-Profit Lotteries, which can also be found in the “documents” section on the permits application page.

The revised documents include more detail on the application process, what the Non-Profit Lottery Terms should consist of, as well as a detailed list of enclosure documents.

Although applicants are urged to refer to the revised requirements at the earliest, these requirements will come into force from 1 May 2024. Hence, any applications submitted following this date will need to abide by the revised requirements. Any applications submitted after 1 May 2024, which are not submitted in full and do not include the proof of payment or the signed declaration, will be set to a one-time “Incomplete” mode for sixty (60) days. If the application is not resubmitted in full, whereby any missing sections and/or documents are filled in and/or uploaded successfully within this period, the application will be rejected and will be closed off. Applications submitted or re-submitted less than seven (7) days prior to the commencement of the tombola session/s will incur the additional twenty-five Euro (€25) non-refundable late application fee.

The Non-Profit Tombola and the Non-Profit Lottery Permits will only be issued upon successful review of the application. Sale of lottery tickets or Tombola sessions cannot be held without the relevant Permit.

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Compliance Updates

DGA: Three Orders and One Reprimand Issued to Mr. Green Limited for Breach of the Anti-Money Laundering Act



Reading Time: 3 minutes


On April 10th, 2024, the Danish Gambling Authority has issued three orders to Mr. Green Limited for breaching the Anti-Money Laundering Act, on risk assessment, on procedures for internal controls and for failing to ensure that controls are carried out.

On April 10th, 2024, the Danish Gambling Authority has also given Mr. Green Limited a reprimand for breaching the rules on notification in the Anti-Money Laundering Act.

The reactions have been given in connection with the Danish Gambling Authority’s inspection of Mr. Green Limited’s materials that Mr. Green Limited has provided for compliance with the Anti-Money Laundering Act.

Order for insufficient risk assessment

Order (a) is issued because Mr. Green’s risk assessment is insufficient, as no separate risk assessment has been made of the individual identified risks associated with Mr. Green’s business model, including payment solutions, and the risk factors associated with it. It follows from section 7(1) of the Anti-Money Laundering Act that undertakings subject to the Act must identify and assess the risk that the undertaking may be misused for money laundering or terrorist financing. The Danish Gambling Authority’s assesses that the risk assessment must include a separate assessment of the risk of the individual payment solutions and delivery channels, as well as a separate risk assessment of the risk factors associated with these. Thus, Mr. Green did not comply with the risk assessment obligation.

Order for insufficient and lack of business procedures

Order (b) is issued because Mr. Green Limited does not have adequate procedures for internal controls, as these do not describe the interval at which controls should be performed. The order has also been given because Mr. Green Limited does not have written procedures on how to monitor that controls are carried out. It follows from section 8(1) of the Anti-Money Laundering Act that undertakings subject to the Act must have adequate written business procedures, which must include internal control. The business procedures should describe how the listed areas are handled in practice. The requirement for internal control also means that there must be controls of whether the controls are being carried out – in other words, that the controls are being checked. Mr. Green Limited has not sufficiently complied with the commitments on business procedures for controls.

Order for lack of documentation of controls

Order (c) is issued because Mr. Green Limited has not documented that controls have been carried out to verify that the internal controls have been performed. It follows from section 8(1) of the Anti-Money Laundering Act that undertakings subject to the Act must document the controls that have been carried out. Thus, Mr. Green Limited has not complied with the obligations to perform controls to ensure that the internal controls are performed.

Reprimand for not making an immediate notification

Reprimand (a) is given because Mr. Green Limited has in two cases not complied with the requirement for immediate notification to the Money Laundering Secretariat. According to section 26(1) of the Anti-Money Laundering Act, an undertaking must immediately notify the Money Laundering Secretariat if the undertaking knows, suspects or has reasonable grounds to suspect that a transaction, funds or activity is or has been related to money laundering or terrorist financing. Mr. Green has not complied with the notification obligations, as there has been no immediate notification.

Duty to act

The orders entail an obligation to act on the part of Mr. Green Limited. Mr. Green Limited must submit a revised risk assessment within June 10th, 2024.

Mr. Green must also within June 10th, 2024, submit a revised business procedure for internal controls and submit prepared business procedures for how the implementation of controls is monitored.

Mr. Green Limited must also submit documentation within October 10th, 2024, that it has been controlled that the controls have been carried out.

The reprimand does not entail any obligation to act on the part of Mr. Green Limited as the breach no longer exists.

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