Yes I believe so too. ACME then has IDs on each scratch off card and forth. It's the price for lowering bitcoins energy level onto a physical medium, you've to introduce a third party that is operating within a legal framework. If ACME sells empty scratch off cards they will be held accountable.
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And even IF you proof that the ecash token is valid, the mint could just not pay out any Lightning invoice and do an exit scam.
Lightning or ecash would introduce even more risks. Once we have involved a third party, we've already compromised enough and don't need to overcomplicate things. Straight on-chain BTC has the least amount of additional risks in this scenario.