More eCOGRA Seals Awarded

[jetset]

Reading some of the posts elsewhere, it occurs to me that the full implications of the eCOGRA eGAP requirements may have been lost in some of the sweeping generalisations that have been made.

For those who are interested in a more balanced view, I am including a link in this post to the relevant section of the eCOGRA site, together with a very brief summary of the broad areas on which Seal casinos are required to comply. Obviously the inspection teams and the applicants have a far more detailed dossier on the regulations to be met, but this gives an idea of the scope, which goes beyond gambling software tests.

http://www.ecogra.org/eGAP/default.asp

eCOGRA Seal Practices and Associated Objectives

The integrity of the eCOGRA seal is principally dependent on the following process :

· whether the seal requirements are sufficient and appropriate;

· the extent to which operators and software providers adhere to these requirements; and

· the effectiveness of the procedures adopted by the Audit Panel firms to ensure compliance

with these requirements.

An exhaustive and detailed schedule of requirements encompassing all areas of online gaming relating to fair gaming practices are incorporated into eGAP. Each practice and its related objective, is summarised as follows :

Player Protection

1. Payment to and Receipts from Players

Payment requests / receipts shall be efficiently and promptly attended to and payments / receipts shall be completely and accurately processed.

2. Minimum Information Requirements

Seal holders shall be required to adequately record certain minimum information relating to player and game activity.

3. Minimum Security Requirements

Information security policies and procedures shall be implemented and maintained to ensure the availability, integrity and confidentiality of gaming operations.

4. Responsible Gaming

A responsible gaming environment that actively discourages problematic gambling shall be established, enforced and monitored.

5. Player and Game Funds

Player balances and game funds shall be sufficiently covered by on demand funds.

6. Player Information

Player accounts shall be managed and accounted for in a secure, safe and efficient environment. The privacy and confidentiality of all player information submitted at any point in time shall be protected from unauthorised disclosure.

Fair Gaming

7. Software Development and Maintenance

Software shall be developed, implemented and maintained in a manner representative of best practice standards.

8. Total Gaming Transaction Review

Games shall be random, independent and fair.

9. Server Connectivity Requirements

Minimum game server connectivity requirements shall be met to ensure that players are protected from losses due to connectivity problems.

10. General Game Characteristics

Seal holders shall adhere to game characteristics that ensure a fair game for a player.

11. Disaster Recovery

eCOGRA seal holders shall be able to demonstrate that they can recover from a system disaster.

12. System Malfunctions

Both the player and eCOGRA's seal holders shall be protected from system and hardware malfunctions.

Responsible Conduct

13. Anti-Money Laundering

Preventative and detective controls addressing money-laundering and fraud risks shall be documented and implemented according to the relevant points in the Financial Action Task Force (FATF) guidelines.

14. Responsible Advertising and Promotions

The seal holder will ensure that players are not mislead through advertising or promotional activities, and will ensure that the terms and conditions of their promotions are followed.

15. Probity Checks

All key individuals and entities involved with members and operators should be credible and not have criminal records.

The Review of System Software

The gaming software is clearly one of the key areas that must be addressed in assessing eCOGRA member and operator eGAP compliance. To meet this objective eCOGRA has developed a highly comprehensive and practical system testing methodology called Total Gaming Transaction Review ("TGTR").

TGTR is an 'outcome-based verification' approach that deviates substantially from the commonly adopted testing of source code which has traditionally been used in the land-based gaming environment (and which has been commonly adopted in the online environment due to a lack of understanding and a better alternative method). In addition to providing a high degree of assurance that the relevant requirements are achieving compliance, this process may be undertaken with minimal disruption to the software provider and operator business activities.

TGTR involves a thorough analysis of every transaction for every game by an independent and trusted third party. This is done by a respected international accounting firm which has been elected to the Audit Panel. This form of review is ongoing, is based on actual transactions and actual game play irrespective of volumes, and can be applied during ongoing system changes and development. Analytical and statistical review ensures the data output is within an acceptable range. This approach also allows for the full investigation of specific queries related to the game play.

It is worth concluding with the point that it's not just about the audit firm being satisfied that the casino operator is meeting the standards - after that the audit firm is required to report their findings to the Independent Directors who must also be satisfied that there is a sufficiently high level of compliance. Both PwC and the Independent Directors' reputations are on the line if a non-compliant casino slips through, so you can expect the process to be extremely thorough.

These are not just idle words on a website - they are firm and detailed requirements addressing player-sensitive areas of any casino operation, and they have to be complied with under inspection and monitoring, and backed by an efficient player complaints system at both casino and eCOGRA itself.

[rowmare]

"To guarantee eCOGRA’s autonomy from software providers and operators, the seals compliance committee is comprised of three independent directors who are not representative of the member software providers or casino operators. These directors are Michael Hirst OBE, former Chairman and CEO of Hilton International; Bill Galston OBE, former Chief Inspector of the Gaming Board for Great Britain; and Frank Catania, a former Assistant Attorney General in the State of New Jersey and former Director of the New Jersey Division of Gaming."

[dominique]

Cute kid, Janet!

Yes, it does seem like there are lots of checks and balances in place. And non microgaming casinos will soon also be certified.

I think players will really benefit from this, and once there is a bit more variey of software, I may well start carrying nothing but eCOGRA approved casinos on my website.

[rowmare]

Thanks, Dom.
That pic was taken at my older daughter's wedding in December. That's her hand on my right shoulder.

[m249a]

As part of my on going campaign against playercenter.com and IGS, I contacted eCogra. My email was promptly replied to, I sent another, and that one was replied to as well. See below.

My email to them;
-----Original Message-----
From: mark altland [mailtoxxx@hotmail.com]
Sent: 23 April 2004 13:34
To: info@ecogra.org
Subject: A question about IGS
Dear Sir/madam,
I have an ongoing dispute with a software provider named IGS. I noticed

that your organisation hasn't approved them yet as a software provider.
If
and when the time comes that you might consider approving them, I ask
that
you take a good hard look at their business practices. They claim on
their
web site to offer a "player gaurantee", however, there is no explanation
of
this,I.E. what requirements need to be met, how much the gaurantee
covers
ect.
I understand you are most likely busy, so I will try to be breif. My
dispute with them is this: In Feb 04 I made a withdraw request from an
online casino named www.islandloescasino.com, to paraphrase the next 2
months of hell, the casino went under several days after i made the
withdraw. I was told by their casheir support www.playercenter.com,
several
times my check was in the mail. After extensive research, and help from
several player advocates, mainly www.casinomeister.com, I finally was
able
to get a telephone confrence with someone from IGS. That confrence is
today
@ 1400 hrs EST. I have proof of a pattern of decietful business
practices as
well as out right fraud. Upon request I will foreward you the emails and

chat logs. I am not asking for help, what I am asking for is for this
type
of behavior be known, and my issue becomes a part of the record. I am
sure
this company will be requesting the seal of approval from your
organisation,
again i ask that you take a good hard look at what type of business
practices they use. Thank you for your time. Mark S.
Altland

Their reply;
-----Original Message-----
From: Tex Rees [mailto:tex@ecogra.org]
Sent: 27 April 2004 13:08
To: 'mark altland'
Subject: RE: A question about IGS

Dear Mark,

I appreciate the effort you have made to contact eCOGRA with your views.
Any software provider that applies to become a member of eCOGRA must
first be accepted as a client of one our Audit Panel members and then
has to be approved by the independent directors on the eCOGRA board.
Your e-mail will be kept on file for future use.

Kind Regards,
Tex Rees

My reply;
-----Original Message-----
From: mark altland [mailto@hotmail.com]
Sent: 27 April 2004 14:50
To: tex@ecogra.org
Subject: RE: FW: A question about IGS

Sir,
Thank you for responding to my concern. I am not someone who is simply
complaining about unfair treatment, or had a streak of bad luck and
wants
the world to hear about it. If and when IGS settles this matter I will
send
you details of that as well. I am not trying to hurt anybody, and if my
case
is settled to my satifaction I would like that made part of the record
as
well. Again, thank you for your time. Mark Altland

His reply:
Hi Mark,

I hope that they do sort out your dispute in the near future, for your
sake and that of the industry. Any follow up information will be greatly
appreciated.

Regards,
Tex Rees


Now, whats the point? Well the point is this guy took time out of his day to respond to my inquiry. I didn't get an auto reply, he typed me a message. I am impressed, and based upon his last message they are looking to see how IGS responds to my case. I'm not trying to deviate from the purpose of the thread, I'm saying it would appear they (eCogra) are trying to be a legimate orginsation. Just my opinion.

[dominique]

Sounds like a good start.

It may be a very good idea to send them complaints - solved and unsolved - to take into consideration when approving casinos.

[m249a]

I couldn't agree more. They are responsive, and they claim to keep our messages on file. I can just imagine them sitting in a smoke filled board room with some new casino owner grilling them "so Mr. Owner, how did you resolve Mr. xyz's problem.....hmmm....and how are you going to ensure that doesn't happen again" that would be great. Maybe, just maybe the players will have a voice in this certifaction process.

[jetset]

The "bad history" thing is an interesting aspect to regulation that I agree should be considered. To be fair, there would have to be a way to produce evidence of such conduct ie email exchanges or the like.

Over time eCOGRA will build up a record of Seal casinos against who complaints have been lodged, but I would guess that for credibility they would have to fire any casino that attracted too many complaints, because that would indicate that they were not compliant with the regulations.

[m249a]

I agree, I think that will be the ultimate test of their integrity. If, and I am sure it will happen, a casino or group gets too many complaints, how they deal with that scenario will show all of us how legit of an orginasation they really are. Time will tell.

[caruso]

I have no problem with Ecogra as a dispute resolution service. Bryan and the other affiliates who help can benefit from having the workload spread around.

The problems are that most Ecogra casinos are solid, apart from Golden Riviera, so disputes should be rare; and most importantly, anyone setting themselves up as an online casino "regulator" who INCLUDES in the package a claim to actually regulate the SOFTWARE will inevitably have this aspect as the major selling point, software integrity being probably the single most contentious aspect of the entire business. You'll help me get paid? Nice. You claim that the software is valid?? Whoa, that's in a totally different league.

Because this aspect of software regualtion is unverifiable / unverified, it must be assumed by DEFINITION that the claim is fallacious. It cannot be taken "on faith".

While Jetset continues to hype this baby of his I will continue to point out that the excercise is currently flawed, and as such the seals are worthless.