The statutes that name dual currency: sweeps bans, read closely

New York wrote the definition down

New York’s S5935A became Chapter 605 of 2025. The Senate record shows it delivered to the governor on 1 December 2025 and signed on 5 December 2025, and the act states that it takes effect immediately.

The definition, added to the Racing, Pari-Mutuel Wagering and Breeding Law, is the part to keep:

• "ONLINE SWEEPSTAKES GAME" SHALL MEAN ANY GAME, CONTEST, OR PROMOTION THAT IS AVAILABLE ON THE INTERNET
• "THAT UTILIZES A DUAL-CURRENCY SYSTEM OF PAYMENT ALLOWING THE PLAYER TO EXCHANGE THE CURRENCY"
• "FOR ANY CASH PRIZE, CASH AWARD OR CASH EQUIVALENTS, OR ANY CHANCE TO WIN ANY CASH PRIZE"
• "AND SIMULATES CASINO-STYLE GAMING, INCLUDING BUT NOT LIMITED TO, SLOT MACHINES, VIDEO POKER, TABLE GAMES, LOTTERY GAMES, BINGO, OR SPORTS WAGERING."

Two tests, joined by "and": the exchangeable second currency, and the casino-style simulation. A promotion that fails either test is outside the definition — which is precisely why the model’s defenders spent years arguing about the first one.

Penalties run from ten thousand to one hundred thousand dollars per violation, with loss of or ineligibility for a gaming licence, and the money collected goes to the Commercial Gaming Revenue Fund for problem gambling education and treatment. Enforcement sits with the State Gaming Commission, the State Police or the Attorney General’s office, which may investigate, hold hearings, issue subpoenas and send cease-and-desist letters. Read the bill record for the full text.

California made it a crime, with a date

California’s AB 831 was signed in October 2025 and, as reported at the time, takes effect on 1 January 2026. The structure mirrors New York’s on the vendor question — liability extends to geolocation providers, payment processors, content suppliers and media affiliates that knowingly and willfully support the platforms — but the sanction is different in kind: a misdemeanour, carrying up to a year in jail and $25,000 per violation, rather than a regulatory fine.

That distinction matters to anyone in the supply chain. A regulatory penalty needs a licence to bite. A misdemeanour does not.

Connecticut and Montana got there first

Connecticut’s SB 1235, enacted as Public Act 25-112, is reported to have taken effect on 1 October 2025, barring unlicensed operators from running sweepstakes that facilitate online casino gaming or sports wagering. Montana’s SB 555 carries the same reported effective date of 1 October 2025.

Both states already licence online gambling in some form, which explains the drafting: the question they answered was not "should casino games be legal online" but "may an unlicensed operator reach our residents by calling the stake a promotional coin".

What the drafting pattern tells a player

Three features repeat across all four statutes, and together they predict how the model unwinds in a state rather than whether it does:

• The second currency is the trigger. A site that stops exchanging its promotional coin for cash is outside the definition — and is also no longer offering what its players came for.
• The supply chain is named. Once payment processors and geolocation vendors carry liability, a site can be shut out of a state by its own suppliers before any enforcement action reaches the operator. From the player’s side this looks like redemptions pausing while the games still load.
• Affiliates and media are named too. Promotion is a separate prohibited act from operation in both the New York and California drafting.

Reading your own position

The practical questions are narrow. Is the state one of those with an enacted statute, and what is its effective date? Does the site still process redemptions there, or only play? Is the promotional balance on the account redeemable at all under the terms, or only the second currency? The sweepstakes hub tracks which brands we list and where.

Where a state has licensed real-money play, that is the alternative, and the licensing position is kept per state:

• State index — every state, with its current position.
• New Jersey, Pennsylvania, Michigan — the largest of the regulated markets.

For the mechanics the statutes are describing, see the two-currency split read from the rules.