...what eCOGRA would have to require is a "Type" of a 100% Surety Bond probably based on the "Player Base Size" essentially insuring each player in their data base for "X" amount of dollars...
I disagree that it should be eCOGRA doing this. They have zero control of any operation beyond the seal, and cannot protect the player against an operator making a run for it.
This should be under the License Issuers control. Have a look at Malta Gaming Licensee's. EVERY operator is required to declare at least one bank account specifically for the use of player balances. The Bank then has to declare to the Lotteries & Gaming Authority that they know the account is for player balances, and confirm that the account cannot be used for anything else. The Licensee, at the end of each month (before the 21st of the following month), then has to provide the LGA with a report of all player balances and liabilities (outstanding cashouts, bets placed for future events etc). The Cash in the bank account must be equal to or more than the player liabilities (and the operator needs to be on standby for a spot audit should the LGA wish to confirm the reports). On top of this, a single individual must be declared to the LGA as a key official (read : Lots and lots of due diligence done on this person), and this key official is PERSONALLY responsible for the full gaming operation.
There are a lot of costs in just setting up an online gambling operation. Choice of License has a lot to play in it :
Curacao : Cheque for $5000 pretty much guarantees it, no background checks.
Kahnawake : from $15000, plus some reasonable due diligence.
Malta : Incorporate company with issued and fully paid up share capital of at least EUR100,000, plus the license application fees, gaming tax etc. Full business plan, 3 year cash forecast, full background investigation on every shareholder & director, testing of RNG required, hardware checks, review of site content, commitment to annual operational audit (between 15 & 30k EUR per time), monthly, biannual and annual reporting, correlated with the tax & VAT departments, and more.
Then there are processing security deposits, set up fee's, dev costs.. and all this excludes having an office with staff sitting around ignoring your phone calls and emails.
On the issue of the seals still being displayed after ecogra pulled them, that is a load of kimshi. While ecogra do not have access to the operators site, they have full control of their own. The seal should be more than just a simple image, (ever seen one of those "hacker Safe" images on an ecommerce website with a date in it). If a user clicks on the image, an ecogra controlled certificate should be displayed.
eCogra say they pulled all the links on the group sites, but if you go to casinoaction.com, click on the ecogra seal at the bottom of the page, you get an ecogra looking page that says :
Accreditation has been awarded to the
casinos listed at www.eCOGRA.org/casinos
on the basis of rigorous assessment by one of a panel of approved
external assessor consultancies of international repute.
Looks nice and legit, till you realise the page is being served by casinoaction and NOT ecogra. eCogra should be out there whacking people with sticks over this
This should be a huge wake up and smack in the face to eCOGRA, and it should result in a big change in the way they report pulled seals. eCOGRA won't suspend a seal for stupid/poxy reasons, but god help the players when a seal is suspended.
and before anyone asks, yes, I do like Malta.