US Sweepstakes Bans: How Single-Currency Models Bypass Regulations

In the world of American online gambling, a high-stakes game of cat and mouse is currently unfolding between regulators and operators. While US states like California and New York are attempting to drive sweepstakes casinos out of the market with new legislation, resourceful operators have already occupied a new niche: single-currency casinos. These platforms abandon the traditional dual-currency system and instead sell digital collectibles to circumvent regulatory hurdles. Since the new laws often explicitly target the combination of two currencies, these new offerings fall through the cracks of the statutes.

The previous sweepstakes casino model was based on Gold Coins for pure entertainment and Sweeps Coins, which could be redeemed for cash. With California's AB 831 taking effect on January 1, 2026, this system was significantly restricted. The industry's response was swift. Providers like Vision NL Limited, the company behind McLuck, launched Card Crush. Here, users do not buy coins but mystery boxes containing digital battle cards. The coins for the slots are merely a complimentary addition, shifting the legal classification from a gambling offer to online retail.

Numbers and facts

The economic importance of these markets is massive. A study by Eilers & Krejcik Gaming estimated player purchases in California alone for 2025 at $2.42 billion, representing about 17 percent of the total US market. Net revenue was calculated at $790 million. In New York, purchases in 2024 amounted to $762 million with a net revenue of $252 million. Together, these two states account for roughly a quarter of the entire market, which was valued at $4.0 billion to $4.6 billion in net revenue for 2025.

The new single-currency sites are growing rapidly. Card Crush recorded approximately 5.4 million visits in the three months leading up to late September 2026, equivalent to about 1.8 million monthly users. This ranks the site 12th among the most visited casino websites in the US, ahead of its sister brand McLuck. The pricing structure is kept simple: coins cost about $2 in standard packages, while welcome offers feature prices of $0.40 to $0.50 per coin. Payouts are possible from 75 Mystery Coins via bank transfer or from 10 coins as a gift card.

Background

The legal core of the new strategy lies in the definition of the bans. California Penal Code 337o and New York's Racing, Pari-Mutuel Wagering and Breeding Law Section 912 both define prohibited products as online sweepstakes games using a dual-currency system. By removing the play-money layer, operators claim they no longer fall under these definitions based on a plain reading of the text. Furthermore, the games are often disguised as card battlers or tournaments, which are not explicitly listed in the prohibited categories for slots or roulette.

Nevertheless, pressure from the judiciary is mounting. New York Attorney General Letitia James announced an $8 million settlement with VGW, the operator of Chumba Casino, on September 9, 2026. The company was required to remain Gold Coin-only in New York. Florida Attorney General James Uthmeier also filed suit against Stake.us and VGW on August 19, 2026, targeting payment processors like Worldpay and Trustly for the first time.

"A ban written around two currencies leaves room for a product with one." - Industry Insider (paraphrased from operator strategy descriptions)

Why it matters for German players

For German players, the situation in the US serves as an important reminder of the significance of clear regulation. While gray-market models flourish in the US, the German market is strictly regulated by the State Treaty on Gambling 2021 (GlüStV 2021). In Germany, there are no sweepstakes casinos with real monetary value that are allowed to operate legally. All providers must be on the whitelist of the Joint Gambling Authority of the States (GGL). For players, this means security but also limitations: a cross-provider deposit limit of 1,000 euros per month applies, monitored via the LUGAS system. Additionally, stakes on virtual slot machines are limited to 1 euro per spin. US models like Card Crush or ZumbaCards do not have a license in Germany and are therefore illegal. Anyone playing in Germany must ensure the casino holds a German license, as only then do player protection measures like the OASIS lock file apply.

What it means for GGL-licensed casinos

Developments in the US show how creatively the unregulated market reacts to bans. For GGL-licensed casinos in Germany, this means they must emphasize their competitive advantage through legal certainty and player protection. While US players pivot to platforms lacking clear consumer protection rules, the German market offers a reliable environment. However, German providers must remain vigilant, as such circumvention models could theoretically attempt to infiltrate the European market. The GGL has already proven it takes strict action against illegal offers through IP blocking and cooperation with payment service providers. A system like the single-currency models would be classified as illegal gambling in Germany immediately, as the deciding factor here is not the number of currencies, but the presence of stake, chance, and the possibility of winning.