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He adds that the recurring weakness is often not an absence of policies but a failure to ensure “technology, algorithms and operational processes actually work in practice”. Some of the QuinnBet issues followed a platform migration, underlining the need to retest controls whenever systems change.
As QuinnBet is also licensed in Gibraltar, Williams expects its regulator to consider the UK’s findings under the jurisdiction’s strengthened Gambling Act 2025. That would not necessarily require a second sanction, but Gibraltar must satisfy itself that any underlying weaknesses have been addressed, he says.
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Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.
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.
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