To: Compliance directors, nominated officers and the executives above them, at operators licensed in more than one market
From: The Gaming Boardroom
Date: 5 October 2026
Subject: Commission nationale des sanctions, Dossier 2025-65, decision of 22 July 2026, published by the ANJ on 21 September 2026
France has sanctioned a licensed gambling operator over anti-money laundering failings for the first time, and the body that did it was not the gambling regulator. The Commission nationale des sanctions, which sits at the Ministry for the Economy, fined the company EUR 20,000 on 22 July 2026 and fined two of its managers personally as well. The whole case rests on one player account and on a screening alert that fired on the right day and then went nowhere.
Key Takeaways
- The Commission nationale des sanctions, which is attached to the French Ministry for the Economy and not to the gambling regulator, fined a licensed online betting operator EUR 20,000 on 22 July 2026 in Dossier 2025-65. The Autorité nationale des jeux inspected and referred the case in July 2025, then published the outcome on 21 September 2026.
- Two individuals were fined personally and given two-month suspended bans on managing an online gambling business: the executive running the company, EUR 20,000, and the manager who supervised the compliance function, EUR 5,000. The legal and compliance officer was cleared, as was the 30.3 per cent beneficial owner.
- The breaches sit under Articles L. 562-4-1 and L. 562-4 of the Code monétaire et financier. A person on the national asset-freezing register opened an account on 3 December 2023, the operator’s own system raised an alert that day, and the account was still confirmed on 14 December with the Minister for the Economy never notified.
What did the Commission nationale des sanctions actually decide?
It decided that having a screening system is not the obligation, and stopping the account is. The control that was meant to catch this did work, since the platform raised an alert the same day the designated person opened the account. The account was confirmed eleven days later anyway, nothing was frozen and nobody told the Ministry, and it took an administrative inquiry the company heard about on 3 January 2024 before anyone went back and closed it.
The defence was that the platform had only just launched, that real money had gone into compliance, and that this came down to human error by an employee on a trial period who has since been dismissed. The Commission rejected all of it, because the asset-freezing duty is an obligation of result rather than of means, so an organisation that generates an alert and then lets the account through has failed whatever was intended. One account was enough. The decision is published anonymised under Article L. 561-40 III, so the operator itself is not named.
Why was the compliance officer cleared and the chief executive not?
The Commission went after the people who were in post and able to decide, which is not the same list as the compliance org chart. The legal and compliance officer was cleared for joining after the account had been opened, and the 30.3 per cent beneficial owner for holding no decision-making role at the time, even though he became chief executive in July 2025.
Personal exposure did not follow the compliance title. It followed the executive running the business and the manager one level above the compliance officer, and the suspended bans mean a repeat would put both of them out of online gambling management for two months.
Who can sanction you for a screening failure in your other markets?
It is rarely the gambling regulator on its own, and in two of the four markets below the heavier penalty comes from somewhere else entirely.
| Market | Who supervises AML for gambling | Who imposes the penalty | Does it reach individuals |
| France | Autorité nationale des jeux, which inspects and refers | Commission nationale des sanctions, at the Ministry for the Economy | Yes. Fines of EUR 20,000 and EUR 5,000 and two-month suspended management bans in Dossier 2025-65 |
| Great Britain | Gambling Commission, for casino operators under the Money Laundering Regulations 2017 | Gambling Commission on the licence, and OFSI at HM Treasury on financial sanctions breaches | Yes. Section 148 of the Policing and Crime Act 2017 allows a penalty on an officer whose neglect allowed the breach |
| Malta | Financial Intelligence Analysis Unit, which is not the Malta Gaming Authority | FIAU administrative penalties, with the MGA acting separately on the licence | Indirectly. The FIAU penalty falls on the company, and the MGA acts separately on key function holder approvals |
| Netherlands | Kansspelautoriteit, Wwft supervisor since 1 January 2016 | Kansspelautoriteit, with sanctions-law supervision of business operations proposed in the second tranche of the Wet internationale sanctiemaatregelen | Proposed penalties of up to EUR 5m or 10 per cent of net turnover, with the scope still in consultation |
Two of these actions came within three weeks of each other and turned on the same thing. OFSI’s penalty against Citibank N.A.’s London branch, imposed on 11 August 2026, records 970 payments worth around GBP 19.7m going through because the designation for Sovcomflot did not match PAO Sovcomflot as the customer records held it. France sanctioned an operator whose alert fired and was ignored, while Great Britain penalised a bank whose alert never fired because of a corporate prefix.
Malta runs the same split routinely, and it was the FIAU rather than the Malta Gaming Authority that fined the remote gaming operator Goldwin Ltd EUR 80,907 on 14 July 2026. The Netherlands is close behind, with the second tranche of the Wet internationale sanctiemaatregelen proposing to hand this supervision to the Kansspelautoriteit.
Recommended Actions
- Test the official lists against your own records rather than against themselves, searching each designation in the forms your records actually use, with corporate prefixes, legal entity suffixes and transliterations included.
- Give every screening alert a named reviewer, a deadline and a written decision, because the French case turned on an alert that existed and produced nothing.
- Make the default block rather than confirm, so an account carrying an open sanctions alert cannot be confirmed or funded until that alert is cleared, and write the rule down.
- Keep one line per licence naming who supervises, who sanctions and who gets told, because France wants notification to the Minister for the Economy rather than to the gambling regulator and Great Britain splits the key event report to the Gambling Commission from the breach report to OFSI.
- Put real names against the executive accountable for the licence and the manager supervising compliance, and have both of them confirm in writing that the alert-handling rule is in place.
Questions for Managers
- When did we last take a designated name from an official list and search for it in the exact form our own customer records hold it, including corporate prefixes and transliterations?
- If a sanctions alert fired on a new account this morning, who owns it, by when must they decide, and can that account be funded while the alert is still open?
- For each licence we hold, which body imposes the penalty for an asset-freezing failure, and is it the same body we would notify?
- Which named individuals here would a regulator join to an action over a screening failure, and have they seen our evidence that alert handling works rather than the policy saying it should?
Sources
1. Commission nationale des sanctions, Dossier n° 2025-65, decision of 22 July 2026, published in anonymised form. Ministère de l’Économie. https://www.economie.gouv.fr/files/files/directions_services/commission-nationale-sanctions/media-document/2025-65_DecisionCNS22072026_JEUX.pdf
2. Autorité nationale des jeux, Lutte contre le blanchiment de capitaux: une première sanction de la commission nationale des sanctions à l’encontre d’un opérateur agréé, 21 September 2026. https://anj.fr/lutte-contre-le-blanchiment-de-capitaux-une-premiere-sanction-de-la-commission-nationale-des-sanctions
3. Code monétaire et financier, Articles L. 562-4 and L. 562-4-1 (asset freezing measures and the internal organisation required to apply them), with Articles R. 562-1 and R. 562-3. Legifrance.
4. Code monétaire et financier, Article L. 561-40 (powers of the Commission nationale des sanctions and publication of its decisions, including in anonymised form). Legifrance.
5. Office of Financial Sanctions Implementation, HM Treasury, penalty notice concerning Citibank N.A. London branch, penalty of GBP 4,732,830.58 imposed 11 August 2026, notice published 2 September 2026.
6. Policing and Crime Act 2017, sections 146 and 148 (monetary penalties for breaches of financial sanctions, and liability of officers of a body corporate). https://www.legislation.gov.uk/ukpga/2017/3/part/8/crossheading/civil-sanctions
7. Gambling Commission (Great Britain), Further guidelines from the Commission regarding Russian sanctions, with Licence Condition 15.2.1 paragraphs 10 and 15 (key event reporting within five working days). https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/further-guidelines-from-the-commission-regarding-russian-sanctions
8. Financial Intelligence Analysis Unit (Malta), Administrative Measure Publication Notice, Goldwin Ltd, administrative penalty of EUR 80,907 imposed 14 July 2026. https://fiaumalta.org/app/uploads/2026/07/Publication-Notice-16072026.pdf
9. Kansspelautoriteit, Wwft en matchfixing (Wwft supervisor for gambling providers since 1 January 2016, reporting of unusual transactions to FIU-Nederland). https://kansspelautoriteit.nl/wwft-en-matchfixing
10. Wet internationale sanctiemaatregelen, second tranche, public consultation documents and explanatory memorandum. https://www.internetconsultatie.nl/tweedetranchewis
11. Regulation (EU) 2024/1624 of 31 May 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, applying from 10 July 2027, which lists providers of gambling services as obliged entities and sets a EUR 2,000 customer due diligence threshold. EUR-Lex.