Gameroom360 | aMOE for operators
Free entry for every sweepstakes gameroom. No purchase necessary.
The Alternative Method of Entry lets players request free Sweeps Coins online or by mail, on the same terms as the Sweeps Coins that come with a Gold Coin package. Use our white-label aMOE in your room, or register your own.
For players
Compliance context
A sweepstakes is lawful only when no purchase is necessary to enter or win. The AMOE is the free way in — and it has to be real, equal and easy to find.
Almost every state treats a game with all three elements as illegal gambling or an unlicensed lottery. A sweepstakes keeps the prize and the chance and removes consideration: nobody has to pay to take part. Gold Coins are sold for entertainment; Sweeps Coins — the only coins that can be redeemed for prizes — are never sold. The AMOE is how a player gets Sweeps Coins without buying anything.
A free entry has to be a real alternative: the same Sweeps Coins, the same games, the same odds and the same prizes as the Sweeps Coins that come free with a Gold Coin package, with no extra hoops. One free coin against hundreds “bonused” with a purchase is the pattern regulators and courts look for.
The official rules must say “No purchase necessary,” that a purchase does not improve the chance of winning, and exactly how to enter free — online and by mail — with the sponsor’s name and mailing address, eligibility, limits, dates and how prizes are awarded.
In its 2023 order against Publishers Clearing House the FTC required no-purchase disclosures that are clear, conspicuous and unavoidable, a direct link to a free-entry page with no sales messaging, and entries kept apart from orders. Players must never be told or led to believe that buying helps.
FTC v. Publishers Clearing House (June 2023)FTC advertising FAQs for small business
An AMOE does not make a room lawful where the model itself is prohibited. New Jersey, Connecticut, Montana, New York, California, Tennessee, Indiana, Maine and Louisiana now have laws aimed at online dual-currency sweepstakes casinos, and Oklahoma’s takes effect November 1, 2026. Regulators in other states (Michigan, Delaware, Arizona, Illinois, Maryland and more) have sent cease-and-desist letters or sued. New York’s law reaches payment processors and platform providers too. Rooms exclude those states and follow their legal opinion.
New York Racing, Pari-Mutuel Wagering and Breeding Law § 912Connecticut General Statutes ch. 743n
Some states add their own steps for big prize pools — for example New York and Florida require registration and a bond when total prizes exceed $5,000, and Rhode Island registers certain retail sweepstakes. Counsel decides which apply to a room.
Processors and card networks treat sweepstakes gaming as high risk. Merchant underwriting asks for the AMOE instructions and checks that the free-entry page is live and linked from the site, and the officer certifies it in the AMOE certification. Without a working AMOE a gameroom cannot be boarded.
This is a plain-language summary for operators, not legal advice. Whether a sweepstakes model is lawful depends on the state, the room’s official rules and its free-entry method; laws change often. Final public rules and AMOE text must be approved by the room’s gaming counsel before anything goes live.
For gameroom owners
Recommended
We host and run the free-entry page for each of your rooms and attach it to your Genesis account.
Already run a free-entry method? Register it on the room and confirm it does what an AMOE has to do:
No. Requesting free Sweeps Coins never asks for payment details, and a purchase never improves the chance of winning.
The Sweeps Coins set in the room’s approved official rules — at least as many as come free with the comparable Gold Coin package. Gold Coins have no cash value and are never redeemable; only Sweeps Coins won in play can be redeemed, after playthrough and identity verification.
As often as the official rules allow — once a day, week or month, or once ever. A second request in the same period, from the same person or player account, is refused without crediting anything.
A room may add a small Gold Coin welcome gift. It is shown separately, has no cash value, and is not the free entry — the free entry is always Sweeps Coins.
Yes. Register it in the owner portal — your free-entry page, official rules and mail-in method — and confirm the checklist. Our team reviews it before your room boards.
No. An AMOE is required, but it does not make a sweepstakes lawful where the model is restricted or prohibited. Your legal opinion and gaming counsel decide where a room may operate.
Attach the white-label aMOE to your gamerooms, or register your own, from the Genesis owner portal.
