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Sweepstakes model (dual-currency)

The sweepstakes model is a way of offering casino-style or poker games without operating as a licensed gambling business, used mainly in the United…

By Anders Lindqvist · CBDM Updated 6 September 2026

Definition

The sweepstakes model is a way of offering casino-style or poker games without operating as a licensed gambling business, used mainly in the United States. It runs on two virtual currencies: a "gold coin" type that is bought or given and has no cash value and cannot be redeemed, and a "sweeps" type that cannot be bought directly but is given as a bonus with gold coin purchases or obtained free by request, and which can be played and then redeemed for cash or prizes.

The legal theory is that because the redeemable currency is never sold and can always be obtained without payment, the activity is a promotional sweepstakes rather than gambling.

The model's status is contested and evolving: some US states permit it, some have moved to restrict or ban it, and regulators and courts continue to examine whether particular implementations are really gambling. Sweepstakes casinos are distinct from social casinos (no redemption at all) and from licensed real-money operators.

In context

For affiliates, the sweepstakes model is a real and sizeable category in the US market and a legitimate thing to cover, but it requires careful, accurate framing because its legal status is genuinely unsettled and varies by state. Content should explain the dual-currency mechanic plainly, that the redeemable currency is obtained free or as a bonus rather than purchased, and that this is the basis for the operator not holding a gambling licence.

It should state clearly which states permit the model and which have restricted or banned it, and keep that information current as the picture changes.

The consumer and responsible-play considerations still apply. Sweepstakes casinos involve spending real money on gold coins to play, with a chance of redeeming sweeps for cash, so players can lose real money even though it is not legally gambling — content should not present it as risk-free or as "not really gambling" in a way that downplays that.

Age restrictions, terms on redemption (minimum thresholds, verification), and the same safer-play messaging appropriate to gambling-like activity should be present. Affiliates should promote only operators complying with the rules of each state they target, should not steer users in banned states toward the model, and should be transparent that the legal basis is a contested one.

Worked example

An affiliate's sweepstakes-casino section explains the gold-coin and sweeps-coin mechanic, that sweeps are obtained free or as a bonus not bought, and that this is the legal basis for no gambling licence. It maps which US states permit, restrict or ban the model, geo-restricts accordingly, notes players can still lose real money, and carries age and safer-play messaging.

Related terms

Frequently asked questions

What does Sweepstakes model (dual-currency) mean?+
The sweepstakes model is a way of offering casino-style or poker games without operating as a licensed gambling business, used mainly in the United States.
Where is Sweepstakes model (dual-currency) used?+
For affiliates, the sweepstakes model is a real and sizeable category in the US market and a legitimate thing to cover, but it requires careful, accurate framing because its legal status is genuinely unsettled and varies by state.
Can you give an example of Sweepstakes model (dual-currency)?+
An affiliate's sweepstakes-casino section explains the gold-coin and sweeps-coin mechanic, that sweeps are obtained free or as a bonus not bought, and that this is the legal basis for no gambling licence. It maps which US states permit, restrict or ban the model, geo-restricts accordingly, notes players can still lose real money, and carries age and safer-play messaging.
What terms are related to Sweepstakes model (dual-currency)?+
Sweepstakes model (dual-currency) is closely related to Sweepstakes casino, Social casino, Regulated market, Age verification, Responsible gaming. Links to each are in the related-terms block below.
Why does Sweepstakes model (dual-currency) matter for operators and affiliates?+
A shared understanding of Sweepstakes model (dual-currency) keeps deal terms, reporting and platform requirements in the iGaming industry unambiguous between partners.
How is Sweepstakes model (dual-currency) different from adjacent concepts?+
The scope of Sweepstakes model (dual-currency) and how it differs from neighbouring concepts is covered in the definition and the related-terms block on this page.
Who owns Sweepstakes model (dual-currency) inside an iGaming company?+
Ownership is shared between the relevant specialist team, analytics and product leadership.
Where can I learn more about Sweepstakes model (dual-currency)?+
The full iGamingB2B glossary carries hundreds of EN/RU definitions — use the search and A–Z index on the glossary page.
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