I'm posting because I have "inside data". By that I do not mean "hidden data", or "secret data", just "inside data".
So, some data. (If some of this is a repeat, then sue me.)
Galewind Software started working with Certified Fair Gambling (CFG, Eliot Jacobson) in February 2009. He performed extensive statistical analysis of our game results, and has continued to do so each month since April 2009.
We obtained an RNG Certificate from CFG in early 2009. We then obtained an RNG Certificate from iTech Labs in June 2010 and again in October 2011 (because of their international accreditations).
We obtained our AGCC Core Services Associate Certificate in June of 2012. Doing this involved 2 different companies:
1. The SQS Group (sqs.com). They performed the analysis/critique/confirmation of all of our games and all of the help files, as well as the analysis/critique/confirmation of our "Administration & Control" systems. In doing this they referred to, and relied on, our iTech Labs RNG Certificate, as well as the 3+ years of statistical game analysis from CFG. (In other words, SQS did not analyze our RNG, and SQS did not do a 1-million game sample analysis of each and every one of our games.)
2. The AGCC (gamblingcontrol.org). A representative/employee of the AGCC flew to one of our offices. They verified that we exist, that I and two of the other developers that work out of that office know our ass from a hole in the ground concerning software, hardware and programming. (The AGCC representative was very experienced in software, as with me going back to Fortran on punch cards for IBM mainframes.) They reviewed corporate tax returns and other corporate documents going back to 2007. They reviewed my personal tax records going back to 2007, as well as the personal tax records of the 3 other Galewind employees that were at this meeting. They also performed "background checks" on our 6 "principals". (One of them, to our never-ending amusement, came back with a false positive for a drug bust in Northern New England.)
So, our company's history of certifications started from the bottom up - RNG certification --> Statistical Game Certification --> Company Certification. In total 4 different companies were involved.
Completion of data. The rest is just speculation and opinion.
If we didn't start from the bottom up, then I do not know what the AGCC audit would have looked like. They may have first required that we obtain an RNG Certificate, then submit large samples (either in one whack or obtained over many months) of each game for statistical analysis (to CFG, or iTech, or TST, or somebody like that). Only then would the AGCC/SQS audit have taken place.
In our case, Pinnacle Sports is a "sole source Casino" - Galewind Software. If this situation happened with Pinnacle, I suspect:
1. Pinnacle would pay all affected players.
2. Pinnacle would then send us the bill.
3. Pinnacle would then call us on the carpet. (There are a lot of very smart people at Pinnacle.) If the problem arose because we screwed up, we might be fired, we might not. If the problem arose because we were something less than ethical, we would be fired, and I suspect that we would also be sued by Pinnacle.
I agree that the first point of responsibility lies with the Casino. If the Casino does not do the "right thing" regarding the Players, then the responsibility falls to the licensing authority, which it seems to me should have the authority to shut the Casino down, and in relatively short order. (In our case, whether the AGCC would cascade down to SQS I don't know, but perhaps that may be true. However, I do not believe that the AGCC can defer or delegate the "top level" responsibility.)
If the Casino does do the "right thing" regarding the Players, then I expect that the scenario I've mapped out above concerning Pinnacle and Galewind would play out. However, I can't imagine that it would cascade from us down to either CFG or iTech Labs. The buck stops at Galewind - we have the ultimate responsibility.
Over the years Galewind has considered then turned down several licensees. One of the "problems" is that with Galewind you don't just get the Casino, you also get the "Galewind Ethos". (So, whether the potential licensee turned us down, or we turned them down, is a point of debate. Either way, the "Galewind Ethos" was an impediment.)
We've also turned down several other licensees because we were, hmm, "disappointed" in the skills/abilities/experience of the people with whom we were assigned to work.
Interestingly, (ironically?) we've also turned down a few because we did not see ourselves as being "just another horse in the stable".
I can say that this kind of shit rocks me down to the soles of my shoes. We're a small company, and we're going to get "lumped in" to that group of companies that seems to be the frequent source of this kind of crap.
Chris
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