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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 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.
