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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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Spillemyndigheden said it contributed actively to this work and sat on FATF’s gaming sector working group. The regulator confirmed that many of the indicators in the report carry relevance for operators licensed in Denmark.

FATF’s warning on illegal and offshore gambling will resonate in Denmark. Last year, Spillemyndigheden secured a court order to block 178 unlicensed gambling sites, the largest such action in the regulator’s history. 

The case highlighted how illegal operators disguise their presence through multiple site variations, a tactic the FATF report also flags as a red flag indicator. 

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