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For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.
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.
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This sense of understanding was also described as something that needed to be maintained continuously, rather than achieved only once and then relied upon.
Consumers reiterated that being informed is an ongoing process, and that fast-paced and immersive gambling formats can rapidly erode awareness.
On the question of who should be responsible for maintaining this understanding, participants favoured a shared model rather than placing the burden solely on one party.
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The distinction matters for crypto businesses. The filing shows regulatory work is moving forward, but exchanges and other market participants cannot yet consider it a set of rules they must adhere to.
The CFTC’s move also comes as other US regulators continue to craft their own crypto policies. The agency and the Securities and Exchange Commission (SEC) jointly issued an interpretation in March on how certain crypto assets would be treated under federal securities laws.
A lot of bigger questions remain without the CLARITY Act. The bill aimed to establish a federal framework for digital commodities and delineate the roles of the SEC and the CFTC.
