who would arbitrate this? with a bond, now the seller can game the system and falsely claim he was scammed by the buyer to earn the bond. they cannot go to court etc.
At least in Bisq arbitrators are people of good reputation who also posted some collateral to do this job and earn some income from doing it.
I believe in case of dispute buyer and seller must submit evidence to convince him to rule in their favor.
In the particular case of a triangulation, the seller would submit evidence of the suing, and the scammer buyer would not be able to submit proof of payment for the sats, as he didn't pay for them.