It’s a bit silly to try to separate the two in this situation.
Even if they want to play that Two Separate entities game, the responsibility still lies on the Casino Group itself.
The Casinos made the decision to authorize the marketing arm to make Lifetime Revenue share agreements with hundreds, or thousands of affiliates to build their business.
Deciding to fire, or close the Marketing entity doesn’t relieve the Casinos of the obligation to fulfill the agreements they authorized the marketing arm to make on their behalf.
That said, their Casinos are eGOGRA Approved, so eCOGRA should officially hold the Casinos responsible for the agreements they authorized their marketing arm to make!
That would be the case in any “Real World” regulation, and yes most of the commissions have control over the relationship and enforcement of Independent Agent agreements.
I imagine the new UK laws would cover this as well.
The MGM Grand could not authorize their Ad Agency to make these kinds of agreements, and then walk away from them just by firing, or switching Advertising Companies.
They’d be sued in New York minute, and lose.
And the Gambling Commission would be all over them to pay as agreed if they were to remain open for business.
eCOGRA has touted itself to be an Online Regulatory Authority of sorts, so they should be very much involved, IMO.