Casino-style games reach players in the United States under more than one legal arrangement, and two of them work very differently. In the first, real-money play rests on state law and a state regulator: New Jersey, Pennsylvania and Michigan each run authorization regimes for internet gaming, and New Jersey and Pennsylvania each publish a list of the operators they have authorized. In the second, the games are offered as a sweepstakes promotion built on two kinds of virtual coin, one of which has no monetary value at all and one of which can become eligible for prizes under the operator’s own published rules. The distinction is not cosmetic. It determines which authority stands behind the site, what the operator must do before it pays anything out, and whether the service may lawfully be offered in a given state at all. What follows sets out how each model works from the player’s side: who authorizes it, who may take part, what the coins do, where legislation targets the sweepstakes model, and what protections a licensed state attaches to the real-money version.

Where real-money play rests on a state license

In New Jersey, Pennsylvania and Michigan, a real-money online casino is not simply a website that accepts wagers. It operates under permission granted through a named state body.

New Jersey publishes the list itself. The Division of Gaming Enforcement maintains an Internet Gaming Sites page listing the internet gaming sites approved to conduct internet gaming operations in the state, and states that any site not on the list is not approved. The list is the test.

In Pennsylvania, the permission has a name. The Pennsylvania Gaming Control Board’s temporary interactive gaming regulations define an interactive gaming certificate as the authorization issued by the Board to a slot machine licensee to operate and conduct interactive gaming under sections 13B01–13B63 of the act, as amended by Act 42 of 2017. The Board describes itself as an independent state agency created by the Pennsylvania Race Horse Development and Gaming Act of 2004, with regulatory oversight of casinos, retail and online sports wagering, online casino-type gaming, video gaming terminals at truck stops and fantasy sports contests.

Michigan’s framework comes from Act 152 of 2019, the Lawful Internet Gaming Act. The Michigan Legislature’s page for the act states that it requires licensure for persons to offer internet gaming and provides for the powers and duties of the Michigan Gaming Control Board, including its jurisdiction and supervision of internet gaming operations.

Who may play, and from where

A license sets conditions on the player as well as the operator, and Michigan’s rules show what those look like in practice. The Michigan Gaming Control Board’s Internet Gaming Rules, at R 432.611(r), define a prohibited person who may not take part in internet gaming to include an individual under the age of 21, which makes 21 the minimum age for online casino gaming in the state.

Location is handled just as explicitly. Rule R 432.631 states that internet wagering transactions must be initiated and received or otherwise made by an authorized participant located in the state, and requires the internet gaming operator and its platform provider to use a geofencing system that reasonably detects an individual’s physical location and blocks access from outside the permitted boundary.

How the two-coin sweepstakes model works

Sweepstakes casinos run on a different premise, and their own terms describe it. The Global Poker Terms and Conditions, version 22.0, state that the platform is owned and operated by VGW GP, part of the VGW Group, that Gold Coins have no monetary value and cannot be redeemed for prizes, and that Sweeps Coins, which can be won in Promotional Play, are sweepstakes entries that become eligible to be redeemed as prizes once played. Chumba Casino’s terms likewise state that Gold Coins do not have any real money value and that a player cannot win prizes in Standard Play, which is played with Gold Coins.

The same terms address the second coin. Global Poker’s terms state that Sweeps Coins may be given free of charge, including via free alternative methods of entry set out in its Sweeps Rules, and that Sweeps Coins cannot be purchased.

Redemption is where the conditions stack up. Chumba Casino’s Sweeps Rules, version 8.0, state that unless the Sponsor/Promoter requires otherwise, any Sweeps Coins allocated to a participant must be played once before they are eligible to be redeemed for prizes, and that the Sponsor/Promoter may require up to 20 plays. The same rules state that a redemption will only be processed if its value is US$100 or more, meaning a minimum of 100 eligible Sweeps Coins. They also state that potential sweepstakes winners are subject to verification by the Sponsor/Promoter in any manner it may choose, that a participant is not a winner until eligibility has been verified, and that the participant’s details must match those of their customer account for a Sweeps Coins prize redemption.

Legislation aimed at the sweepstakes model

California and Connecticut have each moved against the structure in legislation. The California Senate Committee on Public Safety’s analysis of AB 831 states that the bill makes it unlawful to operate, conduct, offer or promote an online sweepstakes game, defined to include games that use a dual-currency system of payment with direct or indirect consideration through which a player may become eligible for a prize, cash or cash equivalents, and that simulates casino-style gambling. The analysis describes the bill as banning online sweepstakes casinos that mimic real-money gambling using a dual virtual system, and lists video poker and table games including poker among the simulated formats covered.

Connecticut legislated separately. The Connecticut Office of Legislative Research’s summary of PA 25-112 states that the 2025 act prohibits anyone not licensed to operate online casino gaming or sports wagering from conducting or promoting a sweepstakes or promotional drawing that allows or facilitates participation in real or simulated online casino gaming or sports wagering, effective October 1, 2025.

The safeguards attached to a license

Licensing also carries obligations aimed at the player’s control over their own participation. A March 2022 Michigan Gaming Control Board news release states that bettors can apply to join the Board’s Responsible Gaming Database to self-exclude for one or five years from all Michigan-authorized providers of online sports betting, online internet casino gaming, or both.

Pennsylvania attaches a duty to the certificate itself. The Pennsylvania Gaming Control Board’s temporary regulations require the compulsive and problem gambling plan of an interactive gaming certificate holder or operator licensee to include a plan for posting the statement “If you or someone you know has a gambling problem, help is available. Call 1-800-GAMBLER” on its webpage and each skin, with compliance with the approved plan a condition of renewal.

Working out which model applies to you

All of which leaves one question for the reader: which of the two is actually open where you are sitting. CasinoTop’s US page on online casinos maps each ranked real-money casino to the states where the site says it verified a license, and is set up for visitors comparing licensed real-money operators alongside sweepstakes alternatives.

The practical work, then, is a two-step check rather than a judgment about which model is preferable. For real-money play, the question is whether a given operator holds authorization in your state, and in New Jersey the Division of Gaming Enforcement says plainly that a site absent from its approved list is not approved. For sweepstakes play, the operator’s own documents govern what the coins do and what must happen before a prize is paid, and Connecticut’s 2025 act bars unlicensed operators from conducting or promoting such a sweepstakes there. In Michigan, licensed internet gaming carries its own conditions on the player: participants must be 21 and physically inside the state.