On this page
A sweepstakes casino looks like an online casino and works, legally, like a promotional sweepstakes. The whole model rests on one sentence: no purchase is necessary. A landing page that makes that sentence hard to find, hard to believe or hard to act on isn't just bad copy. It is evidence against the model it's selling.
This guide covers how the dual-currency model works, what an alternative method of entry has to look like, the state laws that changed the map in 2025 and 2026, and how we build a sweeps page that is clear about all of it. You can click through our demo sweeps page (a fictional brand) as you read.
This is a practical guide for marketers. Sweepstakes law is state law, it changed a lot in the last eighteen months, and it is still changing. Have US gaming counsel review your page and your geo rules before launch.
How the dual-currency model works
Most US states treat a game as an illegal lottery when it has three elements: a prize, chance, and consideration (payment). A sweepstakes removes the third element by offering an alternative method of entry, which is where "no purchase necessary" comes from. Courts have held that the cost of mailing a postcard is too small to count as consideration (Holland & Knight).
Sweepstakes casinos apply that structure with two currencies. Using one large operator's published rules as the example (Chumba Casino Sweeps Rules, v18.0):
| Gold Coins (GC) | Sweeps Coins (SC) | |
|---|---|---|
| What they are | Play currency | Sweepstakes entries |
| How players get them | Purchased in packs, plus free bonuses | Free with marked GC packs, daily bonus, social giveaways, postal request |
| Redeemable? | Never | SC won in play can be redeemed for prizes under the rules (in that example, $1 per SC, from a $100 minimum) |
| Does buying help? | The rules say a purchase will not increase the chance of winning | |
The postal request in those rules is very specific: a 4"×6" blank card, handwritten details and a request code, one card per stamped envelope, sent from the player's home state, earning 5 Sweeps Coins. Detail like that is not bureaucracy for its own sake. It is what makes the free route real and auditable.
The AMOE rules you can't skip
An alternative method of entry has to be more than a footnote. The principles:
- Equal dignity. Free entrants get the same odds and treatment as paying ones, and the process must not be designed to discourage free entry (Holland & Knight).
- Clear disclosure. The FTC puts it bluntly: it is illegal to tell someone to pay to enter a sweepstakes, or that buying improves their odds (FTC). Its 2023 order against Publishers Clearing House required "no purchase necessary" disclosures that are clear, conspicuous and unavoidable, and entry flows separated from order flows (FTC order). That case was about classic sweepstakes, but the logic maps directly onto a coin shop.
- Official rules, linked from every ad and page. State promotion laws expect it: Florida's statute requires ads to carry the rules or the material terms and where to find them (§ 849.094), and New York requires the rules in all advertising for sweepstakes with prizes over $5,000 (GBL § 369-e). Both states also have registration and bonding rules above that threshold.
- Eligibility up front: age (many operators require 21+), excluded states, "void where prohibited".
If you send anything by post, the federal Deceptive Mail Prevention and Enforcement Act adds its own disclosure rules for mailed sweepstakes.
The 2025–2026 crackdown, state by state
The map changed fast. These are the laws we could verify from legislatures or established trade press; trackers disagree on the exact count, and some laws differ in scope.
| State | Law | Status |
|---|---|---|
| Montana | SB 555 | Ban in effect since 1 Oct 2025 (NEXT.io) |
| Connecticut | SB 1235 | Ban enacted June 2025 (Yogonet) |
| New Jersey | A5447 | Signed 15 Aug 2025; covers dual-currency systems (Covers) |
| California | AB 831 | In effect 1 Jan 2026; also reaches payment processors, platforms and media affiliates that knowingly support these games (ZwillGen) |
| New York | S5935-A | Signed 5 Dec 2025, effective immediately; bars media affiliates and others from supporting these games (NY Senate) |
| Indiana | HB 1052 | In effect 1 Jul 2026 (GamblingNews) |
| Maine | LD 2007 | Signed April 2026 (Maine Legislature) |
| Louisiana | HB 53, HB 883 | In effect 1 Aug 2026 (Covers) |
| Tennessee | SB 2136 | Signed 22 May 2026, effective immediately (Gaming Intelligence) |
| Oklahoma | SB 1589 | Veto overridden; takes effect 1 Nov 2026 (Action Network) |
| Iowa | SF 2289 | Not a ban: regulator powers to issue cease-and-desist orders, from 1 Jul 2026 (Covers) |
| Pennsylvania | HB 2801 | Proposed for the 2027 session (Covers) |
Enforcement isn't waiting for legislation either: in August 2026 Florida's Attorney General sued several sweepstakes casino operators and their payment processors over alleged illegal gambling (News4JAX). And many operators have long excluded other states in their own rules: the August 2025 rules quoted above already excluded Connecticut, Delaware, Idaho, Louisiana, Michigan, Mississippi, Montana, Nevada, New Jersey, New York and Washington.
California and New York wrote media affiliates into their laws. "The operator handles compliance" is no longer a complete answer. Geo-exclude banned states in every campaign, geo-gate the landing page itself, keep a dated record of your exclusion list, and re-check it monthly.
Anatomy of a sweeps landing page
Here is how we lay one out, top to bottom:
- Hero: "Play free" is the honest headline, because it is true. Show the free Sweeps Coins on sign-up if there are any, with "No purchase necessary" in the hero, not below the fold.
- Two coins, one screen: what Gold Coins are, what Sweeps Coins are, and the sentence that Gold Coins can never be redeemed. If players can't explain the difference after ten seconds, the page failed.
- Free ways to get Sweeps Coins with equal visual weight: daily login, giveaways and the mail-in request, with a link to the exact instructions. Don't make the free route a grey link in the footer while the coin shop gets a pulsing button.
- Coin packages, if shown at all, framed as Gold Coin purchases with "free" Sweeps Coins as a bonus, never as "buy Sweeps Coins".
- Eligibility strip: age, excluded states, "void where prohibited", links to the Sweepstakes Rules, Terms and Privacy.
- Responsible play: purchase limits, time-outs and self-exclusion in the account, plus a US helpline.
Words to use, words to avoid
Wording on a sweeps page is not cosmetic: it describes which legal model you claim to be. Social modes on platforms follow the same idea. In our slot Vampir's social mode, every "bet" became "play" and every "buy bonus" became "get bonus" (more in our Stake Engine case study).
| Avoid | Use instead | Why |
|---|---|---|
| Bet, wager, stake | Play | No real-money wagering on GC |
| Deposit | Purchase Gold Coins | A purchase, not a deposit |
| Buy Sweeps Coins | Free Sweeps Coins with Gold Coin packs | SC are never sold |
| Win cash / cash out | Redeem prizes | SC redemption under the rules |
| Casino bonus, real money casino | Social casino games, free to play | Describes the actual model |
| "Buy more to increase your chances" | (Nothing. Never say this.) | Exactly what the FTC calls illegal |
Advertising the page
- Google: its gambling and games policy lists sweepstake casinos as an example of games that are not social casino games (Google Ads policy). The social casino route is closed to you.
- Meta: online gambling and gaming ads need account authorisation, the rule covers landing pages including affiliate sites, and ads may not target under-18s (Meta policy). Check how your product is classified before assuming social casino rules apply.
- Industry standards: the Social Gaming Leadership Alliance, launched in 2025, lists "no purchase is ever required to play" and adult-only platforms among its principles (SGLA). If your page contradicts the industry's own principles, it will not survive a regulator's reading.
The pages that will last are the ones that would survive being read aloud by an attorney general. If your conversion depends on players not understanding that Gold Coins are worthless outside the game, you don't have a conversion problem, you have a model problem.
Building comparison pages for sweeps brands as well? The same disclosure logic applies; read the anatomy of a top-10 page, or see our page types on the Growth page.
FAQ
What is an AMOE in a sweepstakes casino?
An alternative method of entry: a free way to get Sweeps Coins, usually a postal request, plus daily login bonuses and giveaways. It removes 'consideration' from the prize-chance-consideration test, and free entries must be treated with equal dignity: same odds, no obstacles.
What is the difference between Gold Coins and Sweeps Coins?
Gold Coins are for play only and cannot be redeemed for anything. Sweeps Coins are sweepstakes entries: they come free with Gold Coin packs or through free methods, and Sweeps Coins won in play can be redeemed for prizes under the sweepstakes rules.
Which states have banned sweepstakes casinos?
Since 2025, states including Montana, Connecticut, New Jersey, California, New York, Indiana, Maine, Louisiana and Tennessee have passed bans, and Oklahoma's takes effect on 1 November 2026. Trackers disagree on the total, and some laws differ in scope, so check each state's current status with counsel.
Can affiliates be liable for promoting sweepstakes casinos?
In some states, yes. California's AB 831 and New York's 2025 law both extend to media affiliates and other businesses that knowingly support these games, not just the operators. Geo-exclude banned states and keep records of how you do it.
Can I advertise a sweepstakes casino on Google as a social casino?
No. Google's gambling and games policy lists sweepstake casinos as an example of games that are not social casino games, so the social casino route does not apply.
18+This article is general information for businesses, not legal advice; sweepstakes law differs by state and changes fast, so check with US gaming counsel before launching. Sweepstakes casinos are for adults only (often 21+). If gambling-style play stops being fun, call or text 1-800-GAMBLER or visit ncpgambling.org.
Sources
- Holland & Knight, Marketers beware: social media sweepstakes and contests (2022): www.hklaw.com/en/insights/publications/2022/05/marketers-beware-your-social-media-sweepstakes-or-contests-could-be
- VGW, Chumba Casino Sweeps Rules v18.0 (Aug 2025): edge.sitecorecloud.io/vgwholdings89e8-vgw-prod-817c/media/250828-POL-CHU-Sweeps-Rules-18-0.pdf
- FTC, Publishers Clearing House consumer alert (June 2023): consumer.ftc.gov/consumer-alerts/2023/06/publishers-clearing-house-deceived-consumers-about-their-sweepstakes-contests-ftc-says
- FTC, Action against Publishers Clearing House (June 2023): www.ftc.gov/news-events/news/press-releases/2023/06/ftc-takes-action-against-publishers-clearing-house-misleading-consumers-about-sweepstakes-entries
- Cornell LII, 39 U.S.C. § 3001 (Deceptive Mail Prevention and Enforcement Act): www.law.cornell.edu/uscode/text/39/3001
- Florida Statutes § 849.094: http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0800-0899/0849/Sections/0849.094.html
- New York General Business Law § 369-e: www.nysenate.gov/legislation/laws/GBS/369-E
- NEXT.io, Tennessee governor signs sweepstakes ban (May 2026): next.io/news/regulation/tennessee-gov-signs-sweepstakes-ban
- Yogonet, Connecticut enacts ban on online sweepstakes casinos (June 2025): www.yogonet.com/international/news/2025/06/17/108479-connecticut-enacts-ban-on-online-sweepstakes-casinos-as-states-move-to-tighten-regulations
- Covers, New Jersey sweepstakes casino ban signed (Aug 2025): www.covers.com/industry/new-jersey-sweepstakes-casino-ban-law-sports-betting-proxy-august-2025
- ZwillGen, California's AB 831 bans sweepstakes casinos (Oct 2025): www.zwillgen.com/gaming/californias-ab-831-bans-sweepstakes-casinos-expands-liability-vendors
- New York State Senate, S5935-A: www.nysenate.gov/legislation/bills/2025/S5935/amendment/A
- GamblingNews, Indiana governor signs sweepstakes ban (Mar 2026): www.gamblingnews.com/news/indianas-governor-signs-sweepstakes-ban-into-law
- Maine Legislature, LD 2007: legislature.maine.gov/legis/bills/display_ps.asp?LD=2007&snum=132
- Covers, Louisiana bills signed (May 2026): www.covers.com/industry/louisiana-gambling-racketeering-bill-signed-by-governor-may-22-2026
- Gaming Intelligence, Tennessee outlaws sweepstakes casinos (May 2026): www.gamingintelligence.com/legal/231081-tennessee-becomes-latest-state-to-outlaw-sweepstakes-casinos
- Oklahoma Legislature, SB 1589: http://www.oklegislature.gov/BillInfo.aspx?Bill=SB1589&Session=2600
- Action Network, Oklahoma ban takes effect in November (June 2026): www.actionnetwork.com/news/oklahoma-sweepstakes-casino-ban-to-take-effect-in-november
- Covers, Iowa regulator powers over sweepstakes casinos (May 2026): www.covers.com/industry/iowa-governor-signs-bill-giving-regulators-power-over-sweepstakes-casinos-may-19-2026
- Covers, Pennsylvania proposal (Oct 2026): covers.com/industry/pennsylvania-lawmakers-propose-ban-on-sweepstakes-casinos-and-500000-dollar-fines-oct-13-2026
- News4JAX, Florida AG sues online sweepstakes casinos (Aug 2026): www.news4jax.com/news/local/2026/08/19/florida-ag-sues-online-sweepstakes-casinos-over-allegations-of-illegal-gambling
- Google Ads Help, Gambling and games policy: support.google.com/adspolicy/answer/6018017?hl=en
- Meta Transparency Center, Online gambling and games: transparency.meta.com/policies/ad-standards/restricted-goods-services/gambling-games
- Social Gaming Leadership Alliance, launch announcement (May 2025): sgleadership.org/social-gaming-leadership-alliance-launches-to-advance-free-safe-and-engaging-online-social-games



