Exclusive interview with Isabelle Falque-Pierrotin – President of the ANJ and GREF

In an exclusive interview, we spoke with Isabelle Falque-Pierrotin, President of the French National Gaming Authority (ANJ) and the Gaming Regulators European Forum (GREF).

For Gambling Club readers who are not yet familiar with you, could you briefly introduce yourself and explain what led you to become President of the French National Gaming Authority?

I was appointed President of the French National Gaming Authority (ANJ) in June 2020 by the President of the Republic, after having led the preparatory mission for this authority for several months. I had extensive experience in regulation from my role as President of the CNIL (French Data Protection Authority) from 2011 to 2019. The challenge of building a new public authority in a sector that is both technological and consumer-oriented seemed a very interesting one to me.

The ANJ and its role

What are the main current challenges in gambling regulation in France? 

The ANJ was established in 2020 to further strengthen player protection by entrusting a single authority with the regulation of the entire sector (online and in physical points of sale). This was previously shared between several administrative authorities, which were not always coordinated.

After five years of regulatory practice, the major challenge or the guiding principle of the ANJ’s strategic plan for 2024-2026 is reducing the number of excessive gamblers by strengthening the identification and support of these gamblers.

We note that the sector’s economic model is too dependent on this population of gamblers and that, moreover, one gambler’s addiction directly or indirectly affects six people.

Three factors maintain, or even increase, the risk of problem or excessive gambling, and they are central to our priorities.

First, the gaming sector is a rapidly growing sector. In sports betting, for example, growth has been double-digit every year for several years. 

Furthermore, the significant illegal offerings, particularly those from unauthorized online casinos, within the current legal framework attract excessive gamblers. Therefore, in line with this general objective of player protection, we are strengthening and diversifying our means of combating the illegal supply of gambling.

Finally, new, more technological offerings are emerging on the fringes of gambling and are particularly attractive to young customers without the protections of gambling legislation. The legislator has chosen to legalize one segment, that of JONUM. We will be involved in the experimental period for JONUM (games with monetizable digital objects), which will begin around September. This will be a richly instructive experiment, and our European neighbors will be following with interest the developments in the situation in France, which is paving the way. We will ensure that solid protection mechanisms are put in place for these new games, which are so popular with young people. 

A final challenge has recently become more pressing: money laundering. While the gambling sector presents a moderate level of risk overall, our mission is to ensure that legal operators comply with all their anti-money laundering obligations. This year, we will strengthen our collaboration with other relevant public authorities.

Does the ANJ exert influence on decisions regarding the evolution of the legislative framework for gambling?

Yes, we are consulted regarding the evolution of gambling and we can also call on the government to request adjustments or the addition of new measures. Of course, we are not always listened to, but our opinion is taken into account.

Player Protection and the Fight Against Addiction

What are the ANJ’s main levers of action to prevent gambling addiction? And how do you assess their effectiveness?

In France, we have implemented both upstream and downstream levers. This is a major difference from the legislation in other European countries, which often focuses more on downstream control.

Upstream, we have various regulatory instruments with regular meetings with operators: action plans to prevent excessive gambling and protect minors, and reviews of promotional strategies. In these plans, operators detail the measures they plan to combat excessive gambling and prevent underage gambling.

Downstream, we monitor compliance with the announced commitments, and we also verify that operators are complying with their various legal obligations, such as compliance with the return to player rate or anti-money laundering measures, etc.

However, the ANJ cannot itself impose sanctions when we observe an infraction, but we can report it to the Sanctions Committee. This is a separate authority from the ANJ board, with its own president, which investigates a case and can decide to impose sanctions. It recently did so against an operator for malfunctions in its self-exclusion system, imposing a public penalty of €800,000.

How does the ANJ monitor compliance with licensed operators’ obligations regarding responsible gaming? 

Each licensed operator submits its action plans annually to the ANJ regarding the prevention of excessive gambling. It is based on these reports that we monitor each operator’s compliance with their various obligations. Furthermore, operators provide us with periodic monitoring of their activities using market indicators.

We also have a tool called the Vault. The Vault receives a real-time data stream containing all transactions carried out on all legal online platforms in France. It’s a big data database containing all online player account transactions. We can compare what operators report with this vault at any time, thus ensuring compliance with their online gambling obligations.

Have you noticed a change in player behavior in France in recent years?

It’s difficult to have a comprehensive view; it depends on the type of game. We only note that they are playing more and more, with an increasing average basket. And they are particularly sensitive to the gamification of their games.

Fighting Illegal Operators

Illegal operators have become a global scourge. What measures are you taking to combat these illegal operators?

Since 2022, we have had the power to administratively block illegal sites. Previously, judicial blocking procedures were lengthy and insufficient in number.

In 2024, the ANJ blocked 1,335 URLs, the same number as between 2010 and 2020, before the administrative blocking power was granted.

We also have excellent relationships with various social media platforms and search engines. By this, I mean Facebook, Google, Twitter, etc., with whom we collaborate to block these sites. We recently worked with KICK to block access for the French public to illegal game streaming.

For the future, we have proposed directly blocking banking transactions to illegal platforms. Many players don’t know the difference between a legal online casino (editor’s note: a casino that only offers online poker) and an illegal one. Preventing them from making a deposit by blocking banking transactions could help limit participation on these sites.

What lessons can France learn from other regulated markets?

We are carefully examining what is being done in other regulated markets to avoid mistakes and improve our regulations.

I take, for example, the problem of gambling advertising. A few years ago, Italy completely banned gambling advertising. Today, they are reversing course because they realized that this was not the best decision, that it gave rise to many circumvention strategies, and that it had had significant negative repercussions on the legal sector and player protection. 

We are therefore not in favor of a total ban on advertising. However, we would like to implement a whistle-ban, which consists of banning sports betting advertising 5 minutes before and after a match, and also during the match. This works very well in other countries, so we believe it would benefit our market.

Another measure we would like to implement would be a loss limit for players aged 18 to 24. These players are particularly vulnerable to gambling addiction. Imposing a deposit limit on them would be a start, but I am convinced that a loss limit would be more effective.

What sanctions are incurred by unauthorized operators who target French players?

Blocking the site, to begin with. This is the first step when we discover that a site unauthorized in France allows French players to access its platform and play.

We have already had French access providers block Cresus Casino, a platform that was well-known to the French public, and Polymarket. 

We are also working with North American regulators to combat casino and betting platforms located in California, in particular, that target French players. It’s working.

Does it make a difference if legal casinos in France’s neighboring countries attract players compared to gray market casinos with Maltese licenses?

There is no difference between a site in a neighboring country that attracts French players and a site located in Malta. So if a Belgian online casino attracts French players, or even allows players domiciled in France to play on their platform, it will be penalized in the same way as a casino located in Malta and not licensed in France. On the other hand, if a French player takes their car and goes to play in a Belgian casino, there is no problem; we do not carry out any checks at this level; the player is free to cross the border to play in other casinos.

The Francophone Network for Gambling Regulation

In early January, you and your French-speaking counterparts from the gambling regulators met at the ICE trade show in Barcelona. Can you tell us more about your shared objectives?

This meeting was the first; it’s a brand new initiative we’ve launched. Currently, the group consists of France, Belgium, Guinea, and the Ivory Coast, but we hope to be joined by other French-speaking countries very soon.

Our common goal is to share our knowledge and perspectives on the gambling market to learn lessons and improve regulations. In France and Belgium, regulations have been in place for many years, while in Africa they lack the same maturity, even though they have access to the same technology.

They will benefit from our expertise and get straight to the point without having to go through years of testing and adjustments. Their regulations will be more effective, more quickly. 

For our part, we will be able to benefit from their new ideas.

The idea behind this group of regulators is also to promote a French-speaking approach to gambling, perhaps a little different from the Anglo-Saxon approach. For example, the importance given to compliance over regulation through sanctions alone is a French specificity and has proven effective in a rapidly evolving technological world.

What lessons can other gambling markets learn from the French experience?

There are two important points that I think could be useful to them.

First, the sports list. This is something we are the only ones to propose. This list sets out the competitions open to betting as well as the types of results permitted. The goal is to improve the quality of the betting offering, promote sporting excellence, and prevent the risks of sports manipulation. For example, with regard to authorized competitions, there must be a certain level, the scores must be properly certified, etc. 

In terms of the type of result, the stakes must be positive, always with the aim of encouraging sporting excellence. Therefore, it’s not possible to bet on a yellow card.

At first, other countries didn’t believe in this sports list, saying it would reduce betting. The figures show the opposite; the sector has never been better and continues to grow every year. Now, other countries want to use it as well. Like Germany, which is considering introducing this sports list into its betting.

And secondly, I would say the safe, this data source so useful for controls.

Have you identified any major differences between the regulatory approaches of different French-speaking countries?

Our association is only a few months old, so it’s too early to say.

Actions of the GREF (Gaming Regulators European Forum)

What is the GREF’s role in gambling regulation in Europe?

The GREF is a platform for exchange and dialogue between various national regulatory authorities. This forum allows members to share their experiences, practices, and knowledge on topics related to the regulation, supervision, and control of operators. It also represents the views of European regulators to national and international authorities and organizations, serving as a central point of contact.

Through its working groups, the GREF enables its members to collaborate around common objectives. I have been chairing the GREF for two years, and I strive to energize these working groups as much as possible. In my opinion, the purpose of these meetings should not only be to meet and discuss. The goal is to exchange best practices and use all these experiences as a basis for concretely improving our respective regulations. 

The GREF’s role is not limited to Europe; it also serves as a central point for discussions with regulators on other continents, particularly North America. I believe it is important to communicate outside of Europe and not remain inward-looking. We have much to learn from the practices of other countries around the world.

What are the main issues addressed by the GREF today?

There are currently five working groups whose main topics are:

• Responsible gaming
• Cooperation in monitoring/sanctions
• Money laundering
• Digital technology and innovation
• Statistics

The statistics working group is particularly interesting because it will allow us to compare market developments in different European countries. This will allow us to see, with figures to support our analysis, which regulatory measures work best and which are least effective.

One topic has come up regularly lately: the harmonization of European gambling regulations. When do you plan to achieve this? Will the GREF participate in this harmonization?

I don’t think this will be implemented in the short term for several reasons. The main one is that each country already has its own regulations, marked by strong cultural and national specificities, and especially its own taxes. I doubt they are ready to give up or reduce this source of revenue in the name of European harmonization.

In this context, the GREF plays a major role. It helps overcome differences and serves as a bridge between these different legislations; ultimately, it will allow regulators to gradually converge towards common operational solutions.

What lessons have you learned from the discussions within the GREF regarding the future of regulation in France?

For us, the GREF is a veritable testing ground; thanks to discussions with other regulators, we can see what works and what doesn’t and draw valuable lessons from it.

Bonus Question

What about online casinos in France? There is already an online gambling market in France, notably poker and sports betting, but will this market be expanded?

There is indeed already an online gambling offering in France. Three games are authorized: sports betting, horse racing betting, and poker. The discussion here is about expanding the online offering, particularly to online slot machines.

The government had launched a consultation on opening the online casino market; this consultation was stopped after the dissolution of the previous government. The new government has not yet relaunched this consultation, and we don’t know if this will happen in the short or long term. But we have already thought about it.

Slot machines, according to numerous studies conducted around the world, are the most addictive games. Authorizing these online games therefore adds a major risk of addiction.

Economic operators argue that players wishing to play online slot machines already do so through illegal sites, and that authorizing these games in France would help dry up the illegal sector by redirecting players to legal platforms. This is true, but it won’t be magical and complete. In countries that have recently opened online casinos, the illegal market remains, and they are still fighting against the illegal sector.

Finally, while the online sector currently represents around 2.5 billion, opening this additional market means opening a new market, almost equivalent. This isn’t just opening a small window, and I can tell you that the major global gaming players are already at our doorstep, ready to seize this opportunity if the sector is opened. Whether all our operators will be ready to compete with these major players is uncertain.

In summary, the ANJ is not against the opening of this new market, but for us, it’s a warning light. If the government decides to go green, we recommend establishing a very strict regulatory framework from the outset (ban on advertising, deposit and loss limits, etc.) to ensure player protection and prevent abuses.

Would you like to add anything?

Yes, I’d like to talk about a recent initiative by the ANJ to combat the “trivialization of gambling.” We are partnering with other groups and associations, such as the National Union of Family Associations and parent-teacher associations, to inform and raise awareness among all stakeholders about this issue.

For example, it seems trivial to offer children a scratch card under the Christmas tree, yet it contributes to the trivialization of gambling. The operators themselves maintain an idealized image of gambling, supposedly bringing easy money, the respect of one’s peers, or a true sportsmanship. In any case, gambling is becoming a daily activity, even though it’s not an ordinary activity due to its potential risks. 

Of course, there’s nothing wrong with gambling, but we must remain aware at all times of the risks of addiction, which can develop very quickly among children and young adults aged 18 to 24. A real cultural shift is therefore needed to change perceptions of gambling in France.