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There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.

“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.

He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

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While the guide does not impose novel legal duties, it effectively tightens the operational framework that operators must observe to manage player fraud in France.

It has addressed ongoing questions faced by operators regarding when it is reasonable to close accounts, withhold or return player balances, cancel bets, or redistribute tournament prizes deemed fraudulently obtained. 

Notably, it has also provided insight into the evidentiary standards French courts expect operators to meet before taking corrective actions that could be subject to legal challenge.

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Although three-quarters of respondents rated their VIP data as good or very good, 71% reported data spread across multiple systems. Half admitted sometimes making decisions with incomplete or outdated information. 

“Silent churn” was prevalent, with nearly half (46%) stating that VIP players often or very often became inactive without prior warning. Around 48% had no indicators of players’ behavioural signals or health. Co-author Viktoriia Grygorenko, CEO at The Playa, called this finding the “clearest commercial case in the report”.

“Every other finding – portfolio overload, fragmented data, reactive workflow, no behavioural signal – resolves here, in revenue that walks out without notice, without warning and without anyone getting the chance to intervene.”