US Sweepstakes Promotional Law

Sweepstakes promotional law is the US legal framework that lets operators such as Chumba Casino run casino-style games without a gambling license. It combines state lottery and sweepstakes rules with a federal mail rule, and operators apply it through a dual-currency Gold Coin and Sweeps Coin model. Since 2025, several states have passed laws aimed at that model, and the map is still moving as of November 2026.

What Does US Sweepstakes Promotional Law Mean?

US sweepstakes promotional law is not a license. It is a set of rules that lets a business give away prizes by chance, provided nobody has to pay to enter. There is no central regulator, no national register and no license number to verify.

The key concept is the lottery. Most state laws, including California Penal Code §319, treat a game as an illegal lottery when it combines a prize, chance and consideration (payment). A lawful sweepstakes keeps the prize and the chance but removes consideration by offering a free way to enter.

At the federal level, the Deceptive Mail Prevention and Enforcement Act of 1999 added sweepstakes rules to 39 U.S.C. §3001(k). It defines a sweepstakes as “a game of chance for which no consideration is required to enter” and requires sweepstakes mailings to state that no purchase is necessary and that a purchase will not improve the chance of winning. The rule governs mailings; it does not authorize online casinos.

The state layer decides whether the model works. Each state has its own gambling, lottery and sweepstakes statutes, and several now name dual-currency casino sites directly. That is why an operator can accept players in one state and exclude a neighboring one.

Sweepstakes promotional law is not a gambling license comparable to a state iGaming authorization or an offshore license such as Curaçao. Operators do not report to a gambling regulator, and their games are not audited the way a licensed casino’s are.

How Do Dual-Currency Sweepstakes Casinos Operate?

Dual-currency sweepstakes casinos give players two balances: Gold Coins for play with no cash value, and Sweeps Coins that can be redeemed for cash or gift card prizes. Only Sweeps Coins won through play can be redeemed.

Gold Coins are sold in optional packages. Sweeps Coins are never sold; they arrive free with marked Gold Coin packages, through daily bonuses and giveaways, and through an Alternative Method of Entry (AMOE). That “free” status is the operators’ argument that no consideration is paid.

The AMOE format varies. High 5 Casino’s Official Rules (version 45.0, October 29, 2026) use a mailed 4×6 request card worth 3 Sweeps Coins. Chumba Casino’s Sweeps Rules (version 27.0, October 30, 2026) use an online entry request: the player handwrites set wording, photographs it in the app and may complete a selfie check.

Regulators who have acted against the model argue that buying Gold Coins with bundled Sweeps Coins is consideration in practice. California’s AB 831, for example, targets games that use “a dual-currency system of payment” to simulate gambling.

Which States Have Acted Against Sweepstakes Casinos?

As of November 2026, New York, California, Connecticut, Maine and Oklahoma have passed laws aimed at dual-currency sweepstakes casinos, and other states have acted through attorney general or regulator enforcement. The table lists actions we confirmed on official government sites.

Other states have restricted or banned sweepstakes casinos through laws, attorney general opinions or cease-and-desist letters that we have not listed because we could not confirm them on an official site. Operator exclusion lists reflect them: Chumba’s current rules also exclude Delaware, Idaho, Indiana, Louisiana, Michigan, Mississippi, Montana, Nevada, New Jersey, Washington and West Virginia.

Why Do Operators Exclude States Without a Ban?

Operators exclude states when they judge the legal risk too high, not only when a ban is in force. That is why exclusion lists differ between brands and change several times a year.

The lists below come from each operator’s own rules or help pages, checked November 2026.

• Chumba Casino (Sweeps Rules v27.0): 17 states excluded, including Oklahoma and Maine.
• High 5 Casino (Official Rules v45.0): 22 states excluded; the rules record that it stopped offering sweepstakes play in Oklahoma on October 29, 2026.
• McLuck (help article, September 16, 2026): 16 states excluded, with promotional contests also unavailable in California.
• Pulsz (Terms of Use v5.2, September 1, 2026): 14 states excluded, with some promotions limited in five more.

Because lists move this fast, the operator’s eligibility clause is the authoritative source for any single brand. Our comparison of sweepstakes casinos tracks these lists in one table.

What Does This Mean for Players?

Sweepstakes casinos remain available in many states, but not in all, and the operator’s own eligibility list is the only reliable check. If your state is excluded, the operator will not let you play for Sweeps Coins or redeem prizes.

• Check eligibility before registering and again before buying Gold Coins.
• Play only from your home state; rules tie eligibility to your verified address and location.
• Meet the age rule: 21 at Chumba, High 5, McLuck and Pulsz.
• Expect identity checks before any redemption.
• Redeem eligible Sweeps Coins promptly if an operator announces an exit from your state.

Using a VPN or a false address breaks operator rules (Pulsz and McLuck say so explicitly) and can void winnings. If you want a licensed environment instead, compare real money casinos and our guide to online gambling laws by state.

Frequently Asked Questions

Where Can You Get Help?

Sweepstakes play uses casino game mechanics, and Gold Coin purchases cost real money. If you need support, see our responsible gambling guide or contact the National Council on Problem Gambling at 1-800-MY-RESET. For how we assess operators, read our review methodology.