France's ANJ issues anti-money laundering guide for JONUM games as Sorare and Eqwin file declarations

What the guide asks JONUM companies to do

France's 2024 law on securing and regulating the digital space, known as the SREN law, created JONUM as a new legal category and placed the companies that offer them under France's anti-money laundering regime, which is set out in the Monetary and Financial Code. The obligations applied from 18 months after the law was enacted. The ANJ is the supervisor for this regime.

The ANJ says the guide is "explanatory, without binding effect". It describes what the existing rules already require:

• Risk assessment. Each company must assess its money laundering and terrorist financing risks in writing, rate them on at least four levels (low, moderate, high, very high) and match its controls to each level. It must be able to send this documentation to the ANJ on request.
• Organisation. A company must appoint a qualified AML/CFT manager senior enough to act, plus at least one Tracfin "declarant" and "correspondent", who may be the same person. It can outsource some tasks, such as funding player accounts through a crypto-asset service provider, but it stays fully responsible. Oversight of the AML system and suspicious transaction reports cannot be outsourced.
• Player identity. Opening a player account counts as entering a business relationship. The company must verify each player's identity and that they are an adult, using electronic identification that meets the Monetary and Financial Code. Staff who check documents must be trained to spot forged documents and identity theft. If a player's identity cannot be confirmed, the relationship must end.
• Higher-risk players. Politically exposed persons, people subject to asset freezes and players living in countries on the Financial Action Task Force (FATF) grey or black lists need additional or enhanced checks. A company that learns one of its players is under an asset freeze must tell the economy minister immediately.
• Suspicious transaction reports. Reports go to Tracfin through its ERMES platform, and attempted transactions must be reported too. The guide says an automated system alone cannot decide to file a report: a person has to review the alert. Telling a player that a report has been filed is prohibited.

The guide gives an example of how money could be laundered through these games. Proceeds of crimes such as ransomware or selling on darknet markets could be used to buy NFTs from a JONUM company. Those NFTs could be sold to buy others and then sold for crypto-assets or cash. They could also be used to play and win fungible crypto-assets that are then moved to other wallets. The ANJ says the sector's built-in vulnerabilities "appear high", because players pay both in euros and in crypto-assets, games are available remotely at any hour, and document fraud is possible. It also says it will publish a separate analysis of money laundering and terrorist financing risks in the JONUM sector.

If the ANJ finds a breach, it refers the case to the National Sanctions Commission (CNS), an independent body. The CNS can issue a warning or a reprimand, ban the company or its managers from the activity for up to five years, impose fines and decide whether to publish the sanction.

Who has declared so far

A company that wants to offer a JONUM in France must first file a declaration with the ANJ. If the file is complete, the ANJ must issue a receipt within 15 calendar days. The ANJ's JONUM page lists five declared offers: CyLimit, Sorare Pro, MFL (Meta Football League), Sorare and Eqwin.

• Sorare filed its declaration on October 2 and received receipt No. 2026-04 on October 7.
• Eqwin SAS filed on October 7 and received receipt No. 2026-05 on October 22. It was published on October 23.

Both receipts state that a receipt "does not prejudge" whether the declared offer complies with the law.

The rules for JONUM

The SREN law defines a JONUM by four combined criteria: a financial outlay by the player, a mechanism that relies on chance, an online service, and the chance to win monetisable digital objects. A digital object counts as monetisable if the player can sell it for value to a third party other than the game company or anyone acting with it. Those criteria overlap with gambling, and the regime is lighter than the one for licensed gambling operators. The ANJ describes it as "a compromise between openness and protection". AskSpinner has also looked at how gacha-style prize mechanics are treated when the prizes can be resold.

The rules published by the ANJ include:

• No cash prizes. A winning player must receive at least one monetisable digital object and can never win euros.
• Capped extra rewards. In-kind prizes, such as match tickets, are limited to €1,000 per player, per game, per calendar year. Some crypto-asset rewards are allowed, excluding stablecoins and asset-referenced tokens, up to 20% of the game's annual revenue and €25,000 per player per year.
• Who can offer and play. Only companies headquartered in the EU, or in an EEA state with a tax cooperation agreement with France, can offer JONUM. Only adults can play.
• Game design. The game must include progression, so that players genuinely get better, and interaction between players or with the game. It must fit a listed genre, such as action, breeding, sports or racing fantasy, adventure, management or racing games.
• Player protection. When opening an account, a player must set a seven-day spending limit and a seven-day playing time limit. Self-exclusion must be available for between 24 hours and 12 months. Since a June 9 ANJ decision, companies must also display a warning message about excessive gambling on their interfaces. Other European regulators have also turned to spending limits, for example the cross-platform deposit caps in Germany and Spain.
• Separate sites. A licensed French gambling operator that wants to offer a JONUM must do so on a different site from its .fr gambling site.
• Data access. Companies must give the ANJ data on players, game events and financial transactions within 30 days of a request. Crypto-asset transactions in the game must be traceable on a blockchain explorer the ANJ can use.

What to watch

• Publication of the ANJ's money laundering and terrorist financing risk analysis for the JONUM sector.
• Further JONUM declarations and receipts on the ANJ's decisions page.
• Whether any JONUM case is referred to the National Sanctions Commission.