In one of the more eye-opening moments from Tuesday’s initial hearing for Indiana’s sweepstakes casino ban bill, House Bill 1052, the general counsel for the Indiana Gaming Commission told lawmakers sweeps casinos are not illegal under current state gambling law.
“It’s nuanced but we don’t think so,” Natalie Huffman said in response to a question from Rep. Steve Bartels regarding if sweeps gaming sites are breaking any Indiana laws, “which is why we need this legislation.
“So, in other states, they think their gambling laws are written in a way that is able to be used against these online casinos, but I don’t think [with] the way that our gambling laws are written we can move forward with sending a cease-and-desist letter in good faith based on current law.”
Why?
“The multi-currency model,” Huffman said, “is what allows it to operate outside our current regulatory scheme.”
Let’s unpack this a little bit.
How dual-currency model interacts with current Indiana law
The following is the current definition of gambling in Indiana:
“Gambling” means risking money or other property for gain, contingent in whole or in part upon lot, chance, or the operation of a gambling device …
When Huffman mentions the multi-currency model, she’s referring to the dual-currency gaming ecosystem employed by today’s sweepstakes casinos — the same dual-currency system directly targeted in Indiana’s bill in those in other sweeps ban bills across the United States, like California and New York in 2025 and Maine and Florida this year.
Sweeps casinos have two types of tokens their players can use:
- Gold Coins, which have no redeemable value and can only be used on-platform.
- Sweeps Coins, which have no real-world value themselves but can be redeemed for cash.
Players cannot directly purchase Sweeps Coins. However, they can purchase these purely-in-game Gold Coins via packages that come with a free bonus of Sweeps Coins. Then, these players can play casino-style games at these sweeps casinos with Gold Coins or Sweeps Coins and, if they win a certain amount of Sweeps Coins, usually 50 or 100, they’re able to redeem those coins at a 1-to-1 rate for cash.
So, 50 Sweeps Coins would redeem for $50.
Sweeps gaming operators consistently emphasize their platforms are not online gambling because players never have to spend a dime to receive Sweeps Coins — as they can also get free Sweeps Coins via perks like daily login bonuses.
Because Sweeps Coins are not actually money and because there are alternative modes of entry (AMOE) to get those Sweeps Coins that are completely free, these operators argue their models shouldn’t be considered illegal online gambling under state laws.
The Indiana Gaming Commission apparently agrees.
Other states, such as Tennessee, Arizona, and Louisiana, where either the state gaming commission or the Attorney General has issued large quantities of cease-and-desist orders to sweeps casinos despite no sweeps ban bills being passed, disagree.
Looking back at legal opinion from April
Huffman’s isn’t the first legal opinion asserting sweeps gaming is currently not illegal in Indiana.
The sweeps casino Spins America — or, more likely its parent company National Sweepstakes Group LLC — commissioned a legal analysis intended for sharing with payment processors back in April, and the law firm behind that legal opinion wrote that if a court were to hear arguments regarding the legality of sweeps, it would determine that online sweepstakes-style casino games are lawful in 33 United States jurisdictions.
And Indiana was one of those 33.
Here’s what the legal opinion, now removed from the links in the footer menu of Spins America, said about Indiana, in part:
The State’s definition of gambling requires a risk of money or other property for gain. Here, players may only obtain redeemable Sweeps Coins for free – Sweeps Coins may not be purchased or obtained for consideration.
In the absence of consideration, the Games do not meet the definition of “gambling” and do not require a gambling license.
The State does not otherwise regulate or prohibit participating in a sweepstakes for an opportunity to win a prize. Sweepstakes are a legal promotional mechanism, where there is an adequate and equal alternative entry method that requires no consideration.
For what it’s worth, the Spins America legal opinion has been pretty accurate with many of the 18 jurisdictions in which it said it could not make a full determination of legality for sweeps gaming, including Connecticut, Kentucky, Maryland, Michigan, Mississippi, Montana, New Jersey, New York, Nevada, and Tennessee.
All of those states have either passed sweeps ban bills or have a strong presence of cease-and-desist orders from a gaming commission or Attorney General.
Lawmakers debating a ban or regulation in Indiana
Huffman’s comments weren’t the only reason Tuesday’s hearing before the House Public Policy Committee was a particularly intriguing one for sweeps operators.
Two lawmakers — Rep. Bartels and Rep. Jim Lucas — advocated regulating sweeps casinos in Indiana instead of banning them. This type of position has been absent from any public-facing legislative discussion regarding sweeps gaming since January 2025 in New Jersey, when Rep. Clinton Calabrese filed a bill that would regulate sweeps operators before pulling the bill in April and, instead, filing another bill that banned sweeps casinos — and that’s the one that was passed and signed into law by Gov. Phil Murphy.
“I don’t think it’s right that an industry found a way to work within the boundaries of the law, and just because we don’t have our ducks in a row to legislate these industries and regulate them, we should punish them by outright banning them,” Lucas said. “It’s incumbent upon us to find a way to make this work, because I don’t think we should be in the business of picking winners and losers.”
No decision was made Tuesday regarding next steps for HB1052.
