Sweepstakes Casino Pivots Won't Escape Legal Risk

Sweepstakes casino pivots away from dual-currency models may not protect operators from state regulators. Gaming attorney Charles Farrell of Dentons US LLP examined four emerging operator model shifts in 2026. Charles Farrell concluded each structure still carries legal exposure.

Four Models, Four Levels of Legal Exposure

The sweepstakes casino sector lost access to six US states in 2026. California, Indiana, Tennessee, Louisiana, Oklahoma, and Maine each enacted bans targeting dual-currency platforms. Operators tested four structural alternatives in response. These were single-currency games, live online bingo, account deposit wagering, and subscription access plans.

Charles Farrell, Senior Managing Associate at Dentons US LLP, identified a shared legal flaw across all four models. The common issue, Charles Farrell told Sweepsy, is whether the product’s economic reality is paid chance-based play for redeemable value. The more a model resembles staking value on casino-style outcomes for cash prizes, the more exposed that model is. ClubWPT Gold replaced its dual-currency Gold Coins and Sweeps Coins system with a single Chips currency. ClubWPT Gold made this switch after California enacted its sweepstakes casino ban. ClubWPT Gold players purchase Hand Analysis credits to access the platform. Bonus Chips arrive with each purchase at no additional cost. Charles Farrell rated the single-currency approach as “still legally dangerous” under regulatory scrutiny.

Thrillaroo operates a subscription-based access model in the US sweepstakes gaming market. Thrillaroo offers three membership tiers at varying prices. Each tier provides access to casino-style games, with full refunds on paid in-game currency losses. Charles Farrell told Sweepsy that subscription wrappers carry significant consideration risk. Charles Farrell said a subscription wrapper likely does not solve the core issue. Charles Farrell explained that regulators will look past the label and test for prize, chance, and consideration. Any subscription where players pay recurring fees for casino-style games with cash prizes likely supplies consideration, Charles Farrell warned.

Account deposit wagering received the strongest rating from Charles Farrell among the four models. Charles Farrell told Sweepsy that account deposit wagering is “likely the most durable if structured properly.” The sweepstakes casino sector also faces more than 100 active class action lawsuits alongside state bans in 2026. Across all four models, the same core question applies. Do players stake value on casino-style outcomes for cash prizes? Any model where that answer is yes carries continued legal exposure. This content is for informational purposes only.