What is AMOE in sweepstakes?

AMOE means alternative method of entry. It is a free way to take part in a sweepstakes, such as sending a postal request, that offers the same chance of winning as entering through a purchase. Promoters use it to show that no payment is required to play, which is the basis for treating the promotion as a sweepstakes rather than an illegal lottery or gambling.

Why do sweepstakes casinos offer free entry by mail?

Because their legal model depends on showing that players do not have to pay to win prizes. Free entry by post, alongside daily log-in and sign-up bonuses, is offered so the operator can argue its redeemable currency is available without purchase. Without a free route, buying coins that can be redeemed for cash would look like paying to gamble.

Does an AMOE make a sweepstakes casino legal?

Not necessarily. An AMOE supports the argument that consideration is absent, but courts and regulators look at how the product works in practice. California's AB 831, in force from 1 January 2026, and New York's 2025 law ban online sweepstakes games using dual-currency systems outright, and other states have taken enforcement action. Legality depends on each state's law.

Is an AMOE required by law?

For mailed sweepstakes, US federal law requires clear statements that no purchase is necessary to enter and that a purchase will not improve the chance of winning. More generally, an AMOE is what allows a promotion with a prize and an element of chance to avoid being a lottery under state law, so promoters treat it as essential. Specific requirements vary by state.

Regulatory

AMOE (Alternative Method of Entry)

Alternative Method of Entry

Definition

An AMOE, or alternative method of entry, is a free way to enter a sweepstakes that gives the entrant the same chance of winning as a paid route, typically by posting a written request or claiming a periodic free allocation. Under most US state laws, an illegal lottery or gambling game needs three elements: a prize, chance and consideration, meaning payment. By offering a genuine no-purchase route, a promoter argues that consideration is absent, so the promotion is a lawful sweepstakes rather than gambling. US federal law reflects the same idea, defining a sweepstakes as a game of chance for which no consideration is required to enter.

AMOE is the legal foundation of US sweepstakes casinos, which give away redeemable Sweeps Coins through mail-in requests, sign-up offers and bonuses attached to purchases. Several states have rejected that argument where, in practice, most redeemable currency arrives with purchases.

Key takeaways

AMOE stands for alternative method of entry: a free route into a sweepstakes with the same chance of winning as a paid route.
It is meant to remove consideration, one of the three elements (prize, chance, consideration) of an illegal lottery or gambling game.
US sweepstakes casinos rely on AMOE, usually postal requests and free bonuses, to argue they are not gambling.
California and New York passed laws in 2025 banning online sweepstakes games that use dual-currency models.

Worked example

An illustrative flow, not any specific operator's terms.

A player who has bought nothing writes a request card with their name, address and account code and posts it to the operator.
The operator verifies the request and credits a fixed number of free Sweeps Coins, the same promotional currency a purchaser receives as a bonus.
The player must play the coins through once on the site's games before they become redeemable.
To redeem winnings for cash, the player passes identity, age and location checks.

The legal argument rests on step 2: if free entrants receive the same chance on equal terms, the operator says no one pays to play. Regulators test whether the free route is genuine and comparable in practice, not just available on paper.

Why it matters

For the US sweepstakes casino sector, AMOE is the difference between a promotional game and unlicensed gambling, so its credibility is a commercial dependency for every company in the supply chain: game studios, aggregators, payment processors, geolocation and KYC vendors, and affiliates.

That dependency is under pressure. California's AB 831, signed on 11 October 2025 and in force from 1 January 2026, bans online sweepstakes games that use a dual-currency system and extends liability to those who knowingly and wilfully support them, including payment processors. New York's governor signed a similar ban in December 2025, and in September 2026 the New York Attorney General announced an 8 million dollar settlement with a leading sweepstakes casino operator, saying players could obtain Sweeps Coins the same way one might purchase chips in a casino. California's law defines the banned games by their dual-currency structure, so offering a free entry route does not take a game outside it.

For B2B companies, the question is no longer only whether an AMOE exists, but which states still tolerate the model, how quickly they act and what liability attaches to suppliers. The sweepstakes and social casino course and the dual-currency model entry explain the mechanics, and the regulatory map tracks the state picture.