I The French technical regulation strategy II The Frontal III. Securing the gaming experience IV. The extended control of the gaming transactions V. Benefits and drawbacks of the Frech technical regulation system VI. Points of contact/Useful links

1. 1
French regulation of online gaming
General presentation of the French technical
regulation system
V1.1 ‐ 2012/09/18

2. 2
I. The French technical regulation strategy
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 A controlled opening of the online gaming market serving the strong regulatory objectives
defined by French Law no.2010‐476 dated May 12th 2010:
 Prevent excessive or compulsive gambling and protect minors.
 Ensure integrity, reliability and transparency of gambling operations.
 Prevent fraud or crime, as well as money laundering and financing terrorism.
 Technical choices adapted to regulatory issues:
 Autonomous access by the regulatory authority to every elementary gaming data
besides data provided by gaming operators, which enables to determine:
 Detailed amount of the stakes:
o Global amount on the market
o Detailed amount for each operator/player‐account/gaming
transaction
 Gaming transaction details: poker games, betting types, allocation of the bets
 Geographical distribution of the bets (IP addresses)
 Market transparency for the regulatory authority:
 In‐depth control of the gaming transactions
 Detection of unusual behaviours:
o Money laundering
o Fraud including sport fraud
o Compliance with problem gambling prevention programs
 Secure online gaming operations for consumers with respect to the protection of
personal data (feasibility of the data treatment without disclosure of the players’
identity):
 Gaming application type‐approval/certification, security audit of the gaming
platforms (analysis of vulnerabilities)
 Player‐accounts control:
o Excluded players
o Moderators (temporary or final self‐exclusion, limitation of deposits,
automatic transfer on paying accounts)

3. 3
 The main device: the Frontal
 Obligation for the gaming operators to put in place an electronic device entitled
« Frontal » between the player and their platform (cf II.)
 Structure of the Frontal:
 Sensor : data capture and formatting, transmission to the vault
 Vault imperatively located on the Metropolitan French territory: securing and
storage in real time of the data, permanently available to ARJEL.
*
French technical regulatory system therefore enables to:
A. Secure the players’ gaming experience
B. Ensure overall extensive control of the gaming operations
The French technical regulatory system is detailed within technical requirements’ file (DET),
enumerating the operator’s general architecture obligations, and its appendix (technical
documentation), available on ARJEL’s website www.arjel.fr.
***

4. 4
II. FRONTAL
***
The frontal is a collection and storage device of the data exchanged between the player and the
operator’s platform during the gaming transactions. The gaming operator is liable for the
development and the operation of this device, accordingly to its general architecture obligations. The
frontal has to be based upon a framework located on the Metropolitan French territory, therefore
enabling in situ controls.
Every transaction between any player considered to be French (declared as a French citizen or
playing from the French territory) and the operator’s platform must pass through the frontal. To this
end, the gaming operator redirects all connections originating from players considered to be French
to its frontal which proxies the data flow.
The frontal device the operators must develop is composed of two main parts:
‐ A traces’ creation function (Sensor), which ensures the collection, the validation and the
formatting of data;
‐ A traces’ storage function (Vault) which ensures a secured storage of logged data. This
function guarantees comprehensiveness, integrity and confidentiality of the logged data
thanks to chaining, time stamping and encryption mechanisms.
Any elementary transaction between the player and a licensed operator will then create a specific
record in the frontal. Elementary transactions are of three types:
1. Financial transaction (deposits, withdrawals,…) ;
2. Player’s account linked transaction (opening, closing, definition of gaming moderators,…) ;
3. Gaming transaction (placing bets, playing poker games).
ARJEL is able to access data whether physically in situ, or remotely at all time.

5. 5
***

6. 6
III. Securing the gaming experience
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Regulation defined by Law and implemented by ARJEL aims at providing the player with a secured
gaming experience by:
1. Systematically homologating any new gaming application or any major evolution of the
gaming application, in each and every of its technical components, when the application
is made available to the player by the operator or through a website. The homologation
procedure enables to check the security level of the application, the unpredictability of
the random number generator used and the accordance of the rules implemented in
the application source code with the rules presented to the players. Homologation
concerns all the components of the application, including the part of it possibly directly
installed on the player’s terminal ;
2. Periodically auditing the gaming platforms of the operators. These audits are of two types:
a. Those performed by entities selected by ARJEL (certifiers) every year in order to
certify the conformity of the architectures implemented with the frame of reference,
b. Those periodically performed by ARJEL itself, in cooperation with the operators, in
order to enhance the security levels ;
3. Providing the operators with an online service allowing the interrogation of the excluded
players’ file, operated and updated by the French Ministry of Interior. This interrogation
must be completed when a player opens an account and then every month ;
4. Monitoring the frontal in order to check its conformity with the technical requirements and
its security level.
Outline of the procedures for securing the gaming experience
***

7. 7
IV. The extended control of the gaming transactions
I. Introduction/Presentation
***
Outline of the procedures for extended control of the gaming transactions
The technical system put in place aims at enabling an in‐depth control of the gaming transactions by
systematically or punctually crossing together data arising from several origins.
ARJEL uses four main types of data:
1. The primary data are the elementary gaming data which are systematically registered and
stored by ARJEL. Originated from the operator’s frontals, these “control data” allow to have
a permanent global vision of all gaming transactions performed on licensed websites ;
2. The “licensing data” correspond to aggregated data provided by the operators on a weekly
or quarterly basis ;
3. The “player/ARJEL data” are punctual data resulting from transactions monitored by ARJEL
or by some players ;
4. The “external data” correspond to data provided by ARJEL’s partners.
The controls on gaming transactions are uppermost grounded upon “control data”. The other types
of data enable to lead complementary controls, namely in terms of coherence because those data
are iterative.

8. 8
II. Types of controls completed by ARJEL
“Control data” also referred to as elementary gambling data, stored by frontals and systematically
collected by ARJEL, are compared, enumerated, associated and analyzed in order to specify “data
indicators”.
[“Money laundering” indicators, “fraud” indicators, “sport events’ integrity” indicators, “operators’
compliance” indicators, “problem gambling” indicators…]
Those indicators can either be generic or specific.
According to specified indicators, “control dash‐boards” are generated for each match or sport
event.
Controls completed by ARJEL can either be scheduled or punctually monitored, on demand.
Automation of the several steps easily enables to get the control dash‐board of a tournament day as
well as the control dash‐boards of each match as soon as the day after the tournament day.

9. 9
III. Example : Monitoring a football match
In order to monitor football matches, ARJEL specified two indicators listings, “standard indicators”
and “advanced indicators”.
Examples of “standard indicators” used for the control of the bets placed on the final results of the
match are presented hereinafter. [Please note that equivalent indicators have been specified for the bets placed on
the several game stages]
 Number of bets placed on the match ;
 Global amount of bets placed on the match ;
 Distribution between single and multiple bets;
 Number of single bets placed on the match ;
 Global amount of single bets placed on the match ;
 Average amount of single bets placed on the match ;
 Number of 1X2 bets placed on the match [single bets aiming at giving the final result of the
match : victory of the hosting team (1), tie (X), victory of the hosted team (2)] ;
 Global amount of 1X2 bets placed on the match ;
 Average amount of 1X2 bets placed on the match ;
 Number ratio of 1X2 bets in comparison to single bets ;
 Amount ratio of 1X2 bets in comparison to single bets ;
 Respective number ratios of bets 1, X and 2 in comparison to 1X2 bets ;
 Respective amount ratios of bets 1, X and 2 in comparison to bets 1X2 ;
 Analysis of most active IP addresses ;
 Analysis of most active player‐accounts ;
 Geographical distribution of bets in number ;
 Geographical distribution of bets in amount ;
 Temporal allocation of bets in numbers ;
 Temporal allocation of bets in amounts.
The results obtained on the considered match are automatically or manually compared to “standard
values” and any gap is pointed out. A match is considered as requiring an alert when a certain
number of indicators depart from “standard values”.
Besides, controls of players, and not only player‐accounts, are completed. Such controls enable to
follow any transaction occurring on all the player‐accounts belonging to the same player on the
platforms of several operators.
An example of bets control completed on the final result of the match is synthetically presented
hereinafter through the detail of some standard indicators. Indicators are qualified by colors
specifying if the value corresponds (green) or not (yellow – orange – red) to standard values.

10. 10
Un
Synthetical analysis of the bets
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Example
FRANCE – ENGLAND
June, 11th 2012
AVERAGE STAKE
(Single bets)
12,74€
AVERAGE STAKE
(Single bets 1X2)
17,11€
AVERAGE STAKE
(1)
18,47€
AVERAGE STAKE
(2)
10,60€

11. 11
Most active IP addresses and player‐accounts
*****
Analysis of the most important stakes

12. 12

13. 13
Analysis of the geographical distribution of bets

14. 14
Analysis of the temporal allocation of bets
Fig 1 : One week before the match
Fig 2 : During the match

15. 15
V. Benefits and drawbacks of the Frech technical regulation system
***
Before listing the main benefits and drawbacks of the system, it seems important to remain the first
strategic reason which has led to choose this particular system. As all technological developments
have been carried out in‐house, therefore guaranteeing a maximal evolution ability and an optimum
control of the system, subcontracting has been restricted to the purchasing of raw materials.
The benefits and drawbacks are enumerated hereinafter after two years of operational monitoring.
Drawbacks of the French technical regulatory system :
The French system requires building an in‐house expert technical team in order to conceive and
create the system.
It imposes a continued progression in order to reach the internal developments.
It binds operators with fix and recurring costs (frontals).
Benefits of the French technical regulatory system
The French model ensures flexibility and perfect control of the system.
It enables to put in place a less expensive system thanks to its in‐house developments.
It allows a direct access to gambling data, namely bets’ amounts and transactions’ details, without
going through a demand to the operator.
It enables a permanent and extensive control of the whole gambling transactions.
It permits an extremely swift treatment of controls and alerts.
It ensures an absolute confidentiality to in‐house developments.
It guarantees a very high security level to the players.
***

16. 16
VI. Points of contact/Useful links
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Points of contacts :
‐ ARJEL’s International Affairs:
Ms Cécile THOMAS‐TROPHIME, Director of Legal and International Affairs (cecile.thomas‐
trophime@arjel.fr)
‐ ARJEL’s Information Technology:
Mr Philippe BRANDT, Head of Information Technology and Evaluation Department
(philippe.brandt@arjel.fr)
Useful links:
‐ ARJEL’s website : www.arjel.fr