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The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.
Operators were encouraged to take several practical steps, including enhancing terms and conditions, maintaining robust evidence and uptaking technical standards.
They have also been advised to thoroughly review their Know Your Customer, fraud detection protocols and contractual terms to reflect the guide’s recommendations.
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“I don’t think the successful studio of the future necessarily has hundreds of people,” he says. “It could be a relatively small group of extremely talented people with great ideas, strong brands and a very good understanding of players, supported by technology that does much of the heavy lifting.”
That would also shift the basis on which studios compete. If sophisticated development capabilities become accessible to a wider range of creators, scale alone becomes less of an advantage.
“It becomes less about how many developers you employ and much more about how creative you are and how well you understand the player,” Curwen says.
How to play Billie Wild
FATF released the report – Risks of Gaming and Gambling – on Wednesday. It updates the body’s 2009 analysis of the casino sector. In addition, it draws on questionnaire responses from 80 jurisdictions and written comments from a further 29, alongside industry consultation.
The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk.
It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.