Good Progress at eCOGRA

24 September 2004

Player protection initiative yielding results

The online gambling self-regulation initiative eCOGRA has been remarkably active since it first began inspecting and accrediting online casinos a year ago, with a variety of recruitment, regulatory updates and marketing projects in full swing.

In a largely unregulated industry, the private initiative operates across geographical and political boundaries, intent on protecting the player through genuine and sensible regulation of the casinos that have committed to its authority.

Forty four casinos have now been awarded the organisation's seal, among them some of the most established and respected brands on the Internet casino scene. More are currently undergoing the stringent independent inspection process required for acceptance.

Poker next....

The pace is likely to increase beyond casino applications. The worldwide poker craze has triggered the framing of new eCOGRA regulations due for public release soon, and negotiations are in progress with a number of leading poker rooms that are interested in committing to serious compliance with a practical regulation regime in the largely unregulated online gambling industry.

eCOGRA followed its usual practice of consulting widely in the formulation of the new poker eGAPs.

Fast resolutions on disputes

Fair Gaming Advocate Tex Rees issues reports on the relatively few disputes with eCOGRA Seal casinos that have been filed online and sorted out - the majority within benchmark-setting timeframes for the industry of less than forty eight hours.

In the current report, the Advocate notes a total of 88 complaints had been received over the past year, although 14 of these were in respect of non-eCOGRA casinos.

Of the remaining 74, most have been lodged over the past three months, perhaps an indication of the growing profile of the organisation and the generous coverage of its activities by leading online gambling portals.

"Of the 74 disputes that we received for approved casinos, 80 percent are made up of bonus and cash-in queries, " she reports. "On the cash-in side most were concerns regarding what the player felt was slow payouts, but on investigation mainly turned out to be associated with slow response to requests for ID verification which were easily resolved."

"There were 25 complaints on bonus issues, and many of these could be attributed to misunderstandings by either players or Support agents that were quickly ironed out. In the sixteen percent of cases where the casino was at fault the issues were immediately redressed, and follow-up action suggests that remedial measures were also introduced to avoid recurrences.

"Seal casinos are reporting increases in activity, and bearing in mind the massive volume of business transacted each month by these very popular casinos, the remarkably low level of problems seems to indicate that the eGAPs are being conscientiously applied."

The success of the mediations is often reflected in some very positive player comments on public message boards.

The Advocate has a few words of advice for players and operators alike.

"Based on my experience in these mediations to date, my advice to players is to read the T&C's very carefully for each and every casino that they play at, as these can vary greatly from one to another. Players should also appreciate that the requests for verification documents are for their protection as well as the casino's and that this is one of the FATF's Recommendations to help combat money laundering, not a ploy by legitimate casinos to slow payments. Players should also check their email filters, where there is a possibility that some responses from casinos are being trapped"
Turning to operators, she said, "It is essential that operators take great care to ensure that information about new promotions and/or changes to their T&C's have been thoroughly communicated to CSR's and the players. Simply by improving in this area, most complaints could be obviated."
The eCOGRA website at www.ecogra.org now sports a more personal look, additional information and new facilities. Taking on board comments and suggestions from the playing community and operators alike, this important facility is now friendlier and more useful to the players, and to casinos and software providers who need further information on the initiative.

Money, fair gaming and T&C regulations updated

Ongoing player and leading industry webmaster input has resulted in updates and new requirements being introduced to the Generally Accepted Practices or eGAP to offer better protection in line with emerging industry trends.

Terms and conditions applicable to promotional activities must now be clearly displayed and shall not be unreasonably altered subsequent to the wagering activity.

To meet international demands for tighter controls the section on anti-money laundering has been revised to include requirements for preventative and detection controls addressing money laundering and fraud risks to be documented and implemented, and where appropriate for controls to be according to the relevant points in the Financial Action Task Force (FATF) guidelines. This has been addressed in order to accommodate the FATF's Forty Recommendations.

Under "Fair Gaming", the Total Gaming Transaction Review requirements have been amended to incorporate additional tests that are being performed by eCOGRA's audit panel members including independent inspection authority PricewaterhouseCoopers.

One example of this change is that wagering activity, including wins, should be distributed amongst an acceptable population of players. This test includes PwC verifying beyond question that a significant sample of the winning players does in fact exist, providing further assurance of data integrity.

Another noteworthy revision is that eCOGRA now requires all games and slots to have a combined average theoretical / estimated statistical return to players of at least (the minimum) 92%. This compares favourably to land-based jurisdictions, such as New Jersey, that requires a return of 83% on slots.

Elsewhere new addendums have been added which detail the requirements to be met when operators who have already been approved add new, or transferred foreign language and foreign currency casinos. These stipulate that seal holding casinos cannot simply add a new casino brand and legitimately display the eCOGRA seal - such changes or additions must go through a comprehensive compliance review by eCOGRA's independent inspection contractor.

eCOGRA CEO Andrew Beveridge urges that players and operators alike communicate with him on suggestions or problems, "We remain very keen to establish a two way flow of ideas and suggestions, which make the organisation stronger and more relevant," he says.

Apart from the initial inspections and ongoing statistical monitoring to ensure fair gaming, seal casinos are required to undergo regular review inspections to ensure that their systems are being maintained to the required standards. This first review cycle is well under way and a number of casinos have already had seal accreditations confirmed.

Improving operational capacity at no cost

eCOGRA operators have benefited beyond increased business from their involvement, because they are now getting detailed professional input that would normally cost tens of thousands of dollars...and it doesn't cost them a cent.

Internationally respected business group PricewaterhouseCoopers has been commissioned to research and provide a series of policy papers covering the optimum professional conduct of business in a variety of operational areas. Management material of this detail and calibre is normally obtained through expensive individual contracts with management consultancies.

"Our goal is to provide casinos that are affiliated with us with every facility to help them achieve high levels of efficiency and thereby ensure the best possible service to the player," says Beveridge.

"The first policy that has been tackled is the critically important topic of security of information. This is designed to meet the eGAP objective "Information security policies and procedures shall be implemented and maintained to ensure the availability, integrity and confidentiality of gaming operations."

The impressive document deals in clear and professional detail with security roles and responsibilities, control of security and other staff, access to information and security systems, password safety, data back-up and recovery procedures, general operational security particularly in regard to email and Internet safeguards, asset classification and control and compliance procedures.

It cautions that information security is integrated in all aspects of a business and as such the scope of the information security policy will impact all entities, including: permanent employees, contractors, temporary employees, third party and outsourced service providers.

"This is just the beginning," says Beveridge. "We will be issuing a series of similarly considered and thorough policies on each critical aspect of running a successful and safe business, all as an added value service to eCOGRA casinos."

Marketing moves

Beveridge and his staff have also been very active in familiarising both players and other interested parties in the industry on eCOGRA's role and goals. An energetic speaker and personal contact program has seen Beveridge and the independent directors interacting with all sectors of the industry at major industry events in Las Vegas, Toronto, Montreal, London and Barcelona, and this will continue.

The active press release campaign to keep eCOGRA in the public eye by making relevant progress reports and information available will continue. In addition, requests for interviews with a diversity of traditional and online media have been carried out in order to explain the eCOGRA concept and its application.

Close personal relationships have been forged with credible government licencing jurisdictions, leading media personalities and portal opinion formers whose voluntary advice continues to be respected and appreciated.

Towards the end of the year a strongly funded pilot marketing campaign across a wide geographic and demographic range will be launched through a leading industry consultancy, and work is well advanced on this project. The results will be used to design and introduce a comprehensive and well funded marketing campaign in 2005.

Anyone can join....but commitment to the ideals is required

eCOGRA is a non-profit, non-partisan body with a full time staff in London, England. Founded in 2002, the organisation spent some time researching the concept of regulation with experts throughout the world before constructing a working set of requirements essential to fair and efficient gambling operations together with an independent inspection and monitoring regime. The first online casinos were accredited in early 2004, and since then a steady stream of online casinos has committed to the eCOGRA ideals and achieved Seal status.

It functions by implementing its player-sensitive set of operating regulations and casino probity requirements through independent inspection and monitoring by internationally respected third parties. Online player dispute services are also available for any player with a legitimate complaint against any eCOGRA operation.

Casinos that have passed the rigorous inspections are identified by an eCOGRA seal, with participation open to any software provider and casino that is prepared to commit to eCOGRA principles of honest operation, fair gaming and efficient financial and customer relationships.

All of the casinos displaying the eCOGRA seal do so only on the understanding that:

(a) the management and the operating entities have to pass real and detailed external probity checks, including financial status

(b) their systems may in some cases have to be reorganised to comply with the eCOGRA requirements and regulations for efficiency and better player service

(c) they agree to be thoroughly inspected by PwC approval and compliance teams that physically stay onsite for up to two weeks, and to address any system found wanting such as Support, accounting, technical, management, staff training, marketing.

(d) they agree to every transaction being monitored and analysed on an ongoing basis by an external agency - the Total Gaming Transaction Review, and to further physical inspections on a regular basis.

(e) they agree to continued adherence to the regulations (called eGAP) which covers every aspect of operational and business conduct and imposes standards.

(f) they agree to promptly deal with any player dispute and if necessary to abide by the (escalated) ruling of the eCOGRA Fair Gaming Advocate if a resolution cannot be achieved at casino level.

It's not something to be entered on lightly and represents a serious commitment to efficiency and fair treatment. All seal holders know that seals can be very publicly revoked as well as awarded.

What does the casino operator get out of the deal?

Experience has shown that the professional review required before acceptance not only involves assessing the software provider and operator levels of compliance, but also provides invaluable consultative feedback from the audit firm on potential internal control issues in areas such as security, anti-money laundering, data protection etc.

The professional studies on highly relevant operational areas have been acclaimed by seal casinos for their value and applicability.

eCOGRA has been involved in dedicated marketing and public relations activities to ensure that industry stakeholders are familiar with the goals of the organisation and the advantages of dealing with eCOGRA approved sites. A Google search of 'eCOGRA' will provide an indication of the type of coverage that is being achieved on many online portals.

The strong funding underpinning these efforts is not drawn from seal casinos, yet there will be obvious benefits flowing from these activities.

eCOGRA's software providers are committed to providing the ongoing funding of the organisation's operational costs, and casino operators are required only to cover the PwC review costs.

** Footnote:
The Board of Directors includes three very well known, and very independent, integrity-driven executives from the broader industry - Michael Hirst, Frank Catania and Bill Galston. These experienced and respected industry leaders control the eCOGRA regulatory and seal award process, as well as its enforcement.