Launch model · US promotional gaming
Sweepstakes Casino
The dual-currency model was a way to run casino-style play in the US without a gaming licence. Nine states have now legislated it away — and New York's statute reaches your payment processor and your platform vendor, not just you.
overview
What is a sweepstakes casino?
A sweepstakes casino runs casino-style games on two currencies. One — usually 'Gold Coins' — is sold and has no redemption value. The other — 'Sweeps Coins' — cannot be bought, is given away with purchases and through a free postal alternative method of entry, and can be redeemed for cash or prizes. The AMOE is the legal hook: because the promotional currency can be obtained for free, the argument runs, there is no consideration, and therefore no gambling.
That argument held for years. It is now being legislated away state by state, and fast. Montana was first, signing SB 555 on 12 May 2025 with effect from 1 October. Connecticut followed with SB 1235 (Public Act 25-112) in June 2025, New Jersey the same year, New York's S 5935A on 5 December 2025 and California's AB 831 — signed 11 October 2025 — from 1 January 2026. Indiana's HB 1052 and Maine's ban landed in July 2026, and Oklahoma's SB 1589 takes effect on 1 November 2026 after a veto override. Washington and Michigan have moved by enforcement rather than a dedicated statute.
Two features of the new laws matter more than the count. First, several were drafted to capture the dual-currency mechanic <em>as a category</em>, regardless of how the AMOE is designed — New York's does exactly that, which removes the free-entry defence entirely. Second, liability extends down the supply chain: New York names payment processors, geolocation providers, content suppliers, platform providers and media affiliates, and California's AB 831 expands liability to vendors, with violations as misdemeanours carrying up to a year in jail and $25,000 per violation. If you supply the sector rather than operate in it, you are now in scope.
your options
How does a sweepstakes casino work?
Keep the dual-currency model and block every state that has banned it, with the map maintained as legislation moves. Viable today, and structurally shrinking — plan on the assumption the list keeps growing.
Drop the redeemable currency entirely and run play-for-fun. Removes the gambling analysis in most states — but not automatically, as Washington's case law shows. See the social casino guide for where that line actually sits.
In the states that regulate online casino, take the licence. Highest barrier, and the only route that is not one legislative session away from closing.
If the US is optional, an offshore gaming licence gets you a real-money product across the rest of the world without the sweepstakes fiction. Usually the cheapest path to a durable business.
head to head
Sweepstakes vs. social vs. licensed real-money
| Sweepstakes | Social casino | Licensed iGaming | |
|---|---|---|---|
| Cash redemption | Yes, via promo currency | No | Yes |
| Gaming licence | Not the model's basis | Not usually | Required |
| US state coverage | Shrinking — 9 banned | Wider, not unlimited | Only licensed states |
| Supplier liability | Yes in NY & CA | Limited | Licensed suppliers |
| Payment risk | High — processors named in NY | Moderate | Regulated rails |
| Regulatory direction | Closing | Under scrutiny | Expanding |
requirements
What you need to launch a sweepstakes casino
step by step
How to launch a sweepstakes casino
- Map your exposure We take your player states, your product and your contracts and tell you where the model is prohibited, where it is contested, and where you are exposed as a supplier. Day 1
- Pick the durable model Sweepstakes with a tight map, social with no redemption, or a licence. We are blunt about which of the three survives your five-year plan. Week 1
- Structure and licence Company, licence application and compliance programme for whichever route you take — including offshore permits for the non-US side of the business. Week 2–10
- Banking and monitoring Payment rails that will price the model you actually run, plus a legislative watch so a new ban never surprises your geo-fence. Ongoing
Want the shortlist for a sweepstakes casino?
Tell us your product, target markets and payment mix — we'll confirm the route that gets you live fastest at the lowest all-in cost, with the number itemised.
costs
How much does a sweepstakes casino cost?
US sweepstakes law is moving every legislative session, and the state list above is our reading as of August 2026 — we re-verify it against the statutes at scoping and we will tell you if it has moved. Nothing here is legal advice for a specific state; where a launch turns on one state's statute we work alongside US counsel. Licence figures are regulator schedules and mirror our jurisdiction pages.
go deeper
Which licence a sweepstakes casino needs
Sweepstakes casino FAQ
What is a sweepstakes casino?
A casino-style site running on two currencies: a purchasable coin with no cash value, and a promotional coin that cannot be bought, is given away with purchases and through a free alternative method of entry (AMOE), and can be redeemed for prizes. The AMOE is what the model relies on — with a free route to the redeemable currency, the argument is that there is no consideration and therefore no gambling.
Are sweepstakes casinos legal in the US?
Less every year. Nine states have statutory bans in force or dated: Montana (SB 555, effective 1 Oct 2025), Connecticut (SB 1235 / PA 25-112, 2025), New Jersey (2025), New York (S 5935A, 5 Dec 2025), California (AB 831, 1 Jan 2026), Indiana (HB 1052, 1 Jul 2026), Maine (Jul 2026), Tennessee, and Oklahoma (SB 1589, 1 Nov 2026). Washington and Michigan have acted through enforcement instead of a dedicated statute. The list is our reading as of August 2026 and it moves every session.
Does an AMOE still protect the model?
Not in the states that have legislated. The newer statutes were drafted to capture the dual-currency mechanic as a single category regardless of AMOE design — New York's does precisely that. A well-run AMOE is still necessary where the model remains available, but it is no longer a defence in the states that banned it.
Am I exposed if I only supply sweepstakes operators?
Yes, in at least two states. New York's statute names service providers explicitly — payment processors, geolocation vendors, content suppliers, platform providers and media affiliates. California's AB 831 expands liability to vendors and makes violations misdemeanours carrying up to a year in jail and $25,000 per violation. If you process, host, supply games to or market for the sector, map your own exposure, not just your clients'.
Do I need a gaming licence for a sweepstakes casino?
The model is built precisely on not needing one — that is its entire point, and its entire fragility. If you want a durable US real-money product, the answer is a state iGaming licence in the states that offer one. If the US is optional, an offshore gaming licence gives you a licensed real-money product everywhere else, usually for less than the compliance cost of defending the sweepstakes model.
What is the difference between a sweepstakes casino and a social casino?
Redemption. A sweepstakes casino lets players convert a promotional currency into cash or prizes; a social casino does not pay out at all. Removing redemption removes most of the gambling analysis — but not automatically: Washington case law has treated non-redeemable virtual chips as a 'thing of value'. The line is narrower than it looks.
other products
Looking at a different launch model?
Reviewed by the Vantegris licensing team. This page is general information, not legal advice. Fee schedules and timelines mirror our jurisdiction pages and change when regulators change them.
Free consultation
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