Gaming Authorization & Compliance Model
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♠ O N P O I N T C A S I N O . C O M
Gaming Authorization &
Social Sweepstakes Compliance Model
OnPoint Administration LLC
EFFECTIVE DATE: SEPTEMBER 11, 2026
LAST UPDATED: SEPTEMBER 11, 2026
OnPoint Administration LLC, a Delaware limited liability company ("OnPoint," "we," "us," or "our"),
operates OnPointCasino.com (the "Platform"), a social sweepstakes casino for adults in permitted U.S.
jurisdictions. This document explains the basis on which the Platform operates, how its social
sweepstakes model is structured, and the legal, operational, and financial crime controls OnPoint
maintains. It is intended for payment processors, banking institutions, business partners, and other
stakeholders.
OnPoint does not offer real-money gambling. Sweeps Coins are never sold, no purchase is ever necessary to
participate in sweepstakes or win a Prize, and a purchase does not increase any participant's chances of winning.
Sweepstakes are void where prohibited by law.
Company Overview
ITEM DETAILS
Legal entity OnPoint Administration LLC, a Delaware limited liability company
Business model Social sweepstakes casino using a dual-currency model (Gold Coins and Sweeps Coins)
Market Adults 18+ (or the age of majority, if higher) located in permitted U.S. jurisdictions
Mailing address 8080 N Central Expy, Suite 1700, Dallas, TX 75206, United States
Compliance contact support@onpointcasino.com
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CONTENTS
01 Executive Summary 09 Payment and Redemption Controls
02 Gaming Authorization Status 10 Responsible Gaming
03 Legal Framework: Sweepstakes vs. Gambling 11 Game Integrity and Fair Play
04 The Dual-Currency Model 12 Marketing and Affiliate Standards
05 No Purchase Necessary and Free Entry 13 Consumer Protection and Transparency
06 Jurisdictional Controls 14 Data Protection and Security
07 Eligibility and Identity Verification 15 Compliance Governance and Ongoing Review
08 AML and Sanctions Compliance 16 Contact Us
01 EXECUTIVE SUMMARY
The Platform is built on a compliance model with ten core pillars, each described in this document:
PILLAR SUMMARY
Promotional sweepstakes structure Designed so that the element of consideration is absent from sweepstakes
participation
Dual-currency model Gold Coins for entertainment only; Sweeps Coins are free and are the only path
to Prizes
No purchase necessary Multiple free methods of entry, including an always-available mail-in method
Jurisdictional controls Restricted states blocked through geolocation, identity verification, and
legislative monitoring
Identity and age verification Tiered KYC, with full verification required before any Prize redemption
AML and sanctions compliance Risk-based AML program, OFAC and PEP screening, and transaction monitoring
Payment and redemption controls Own-name payment methods, verified redemptions, and play-through
requirements
Responsible gaming Purchase limits, cool-off periods, self-exclusion, and support resources
Consumer protection A complete, published policy suite and a structured complaint process
Governance Designated compliance leadership, outside counsel review, and ongoing policy
review
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02 GAMING AUTHORIZATION STATUS
OnPoint does not offer real-money casino gaming or lottery products and does not hold a state gaming license.
The Platform is structured and operated as a promotional sweepstakes under U.S. state sweepstakes and
promotion laws. Under this model, participants never pay to enter a sweepstakes, which is the basis on which
OnPoint operates without a gaming license in permitted jurisdictions.
OnPoint's authorization framework is built on four principles:
• Operate only where permitted. The Platform is available only in jurisdictions where OnPoint, with the
guidance of counsel, has determined that the social sweepstakes model may be offered.
• Restrict promptly. Where a state prohibits dual-currency sweepstakes, requires a license OnPoint does not
hold, or presents enforcement risk that OnPoint determines is unacceptable, that state is added to the
Restricted Jurisdictions list and geo-blocked.
• Comply with promotion laws. Where state promotion laws impose registration, bonding, or disclosure
requirements, OnPoint evaluates and complies with those requirements with the assistance of counsel.
• Monitor continuously. Legislative, regulatory, and enforcement developments are tracked on an ongoing
basis, and controls are updated as the legal landscape changes.
Important: This document is a summary of OnPoint's compliance model. It is not a gaming license, a legal opinion,
or a guarantee regarding the legal status of sweepstakes in any jurisdiction. Laws governing social sweepstakes
vary by state and are changing rapidly. The Terms and Conditions, Sweepstakes Rules, and other published
policies govern the relationship between OnPoint and its users.
03 LEGAL FRAMEWORK: SWEEPSTAKES VS. GAMBLING
Under the laws of most U.S. states, an activity is generally treated as gambling or an unlawful lottery when three
elements are present together: a prize, an outcome determined by chance, and consideration paid to
participate. Lawful promotional sweepstakes offer prizes awarded by chance but remove the element of
consideration by ensuring that no purchase or payment is required to enter or win.
ELEMENT PRESENT? HOW THE MODEL ADDRESSES IT
Prize Yes Eligible Sweeps Coins may be redeemed for Prizes in accordance with the
Sweepstakes Rules.
Chance Yes Game outcomes are determined by random number generation.
Consideration Designed to be
absent
Sweeps Coins are never sold and can be obtained through free methods of
entry. Gold Coins are sold as an entertainment product with no redemption
value, and any Sweeps Coins provided alongside a Gold Coin package are a
free promotional bonus. Sweeps Coins obtained for free are identical to all
other Sweeps Coins.
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State laws are not uniform. A growing number of states have enacted statutes that specifically prohibit
dual-currency sweepstakes models, regardless of the availability of free entry. OnPoint treats those states as
Restricted Jurisdictions (see Section 6).
At the federal level, the Unlawful Internet Gambling Enforcement Act (UIGEA) applies to bets or wagers that are
unlawful under the applicable federal or state law where they are made. Because the model is designed so that
participants never pay to enter a sweepstakes, and because the Platform is restricted in states that prohibit the
model, OnPoint's controls are designed to keep Platform activity outside that scope.
04 THE DUAL-CURRENCY MODEL
FEATURE GOLD COINS SWEEPS COINS
Purpose Entertainment play only Participation in sweepstakes promotions
Can be purchased? Yes, or obtained free Never. Always provided free of charge
How obtained Purchase, promotions, free rewards Free methods of entry, promotions, or a free
bonus with Gold Coin packages
Monetary value None None, unless validly redeemed
Redeemable for Prizes? Never Yes, subject to KYC, play-through, and the
Sweepstakes Rules
Transferable? No No
Gold Coins and Sweeps Coins are maintained as separate balances. Users are informed at the point of purchase
that they are purchasing Gold Coins, that Gold Coins cannot be redeemed, and that no purchase is necessary to
participate in sweepstakes.
05 NO PURCHASE NECESSARY AND FREE ENTRY
Free entry is central to the model. As detailed in the Alternative Method of Entry Policy, eligible players may
obtain Sweeps Coins for free through the Daily Wheel, daily, weekly, and monthly quests, website requests,
postal mail-in requests, social media bonus drops, community chat drops, and other free promotions. The model
is governed by the following equal-treatment principles:
• Identical coins. Sweeps Coins obtained for free have exactly the same value, play-through requirements,
redemption minimums, and Prize eligibility as all other Sweeps Coins.
• Always-available mail-in. A postal mail-in method remains available for as long as the sweepstakes
promotion is offered.
• No purchase advantage. Purchasing Gold Coins never improves a participant's odds of winning a Prize.
• Clear disclosures. "No Purchase Necessary" and "Void Where Prohibited" statements appear in the Terms
and Conditions, Sweepstakes Rules, AMOE Policy, and at the point of purchase.
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06 JURISDICTIONAL CONTROLS
STATUS MEANING CONTROLS
Permitted Jurisdictions where OnPoint has determined the
model may be offered
Full access for eligible, verified users
Under Review Jurisdictions with pending legislation, regulatory
inquiries, or enforcement activity
Heightened monitoring and counsel review;
restriction implemented if warranted
Restricted Jurisdictions where the model is prohibited or
OnPoint has elected not to operate
Blocked at registration, purchase, gameplay,
and redemption
As of the date of this document, the following states are Restricted Jurisdictions:
• California • Maine • New York
• Connecticut • Michigan • Oklahoma
• Idaho • Montana • Tennessee
• Indiana • Nevada • Washington
• Louisiana • New Jersey
The Platform is also unavailable outside the United States. Jurisdictional status is enforced through the
following controls:
• Geolocation. IP-based and, with permission, device-based location checks at registration, login, purchase,
and redemption.
• Location masking detection. Detection and blocking of VPNs, proxies, and other location-spoofing tools.
• Residency verification. Residential address verification through KYC, so that residents of Restricted
Jurisdictions cannot participate from elsewhere.
• Legislative monitoring. Ongoing tracking of state legislation and enforcement activity with counsel, with
geo-blocks implemented on or before the effective date of any prohibition.
• Wind-down procedures. When a state is newly restricted, affected users are notified and handled in
accordance with the Terms and applicable law.
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07 ELIGIBILITY AND IDENTITY VERIFICATION
All users must be at least 18 years of age (or the age of majority in their jurisdiction, if higher), reside in and be
located in a permitted U.S. jurisdiction, and hold only one Account. Identity verification is performed with a
specialized third-party provider using a tiered approach:
STAGE WHEN IT APPLIES WHAT IS VERIFIED
Registration Account creation Name, date of birth, address, email, phone, age, and
location
Full KYC Before the first Prize redemption, at
risk-based thresholds, or on risk indicators
Government-issued photo ID, selfie and liveness
check, proof of address, sanctions and PEP
screening
Enhanced Due
Diligence
High-risk Accounts or unresolved red
flags
Source of funds and source of wealth, with senior
compliance review
Duplicate Accounts, underage users, and users whose identity cannot be verified are blocked, and any
associated Virtual Coins are voided in accordance with the Terms.
08 AML AND SANCTIONS COMPLIANCE
OnPoint maintains a risk-based anti-money laundering and sanctions compliance program, described in its
Anti-Money Laundering Policy and designed with reference to the Bank Secrecy Act, the USA PATRIOT Act,
OFAC regulations, and FinCEN guidance. Key elements include:
• A designated AML Compliance Officer reporting directly to OnPoint's members;
• Customer risk ratings and enhanced due diligence for higher-risk Accounts;
• Screening against OFAC and other U.S. sanctions lists at onboarding and on an ongoing basis, together with
PEP and adverse media screening;
• Automated and manual transaction monitoring for red flags, such as minimal-play redemptions, structuring,
and linked Accounts;
• Reporting of suspicious activity to FinCEN and other authorities as required or permitted by law;
• Record retention for a minimum of five (5) years; and
• Staff training at least annually and periodic independent testing of the program.
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09 PAYMENT AND REDEMPTION CONTROLS
CONTROL DESCRIPTION
Payment processing Payments are processed by third-party payment processors. Card data is tokenized, and
OnPoint does not store full card numbers.
Own-name payments Purchases may only be made with payment methods registered in the Account holder's
name. No cash, money orders, or third-party payments are accepted.
Verified redemptions Prizes are paid only after full KYC, to a verified redemption method in the Account
holder's name.
Play-through requirements Sweeps Coins must be played through before redemption, preventing the Platform from
being used to move funds without genuine gameplay.
No peer-to-peer transfers Virtual Coins cannot be transferred, gifted, sold, or exchanged between Accounts.
Limits Purchase, redemption, and velocity limits are applied based on risk and responsible
gaming settings.
Chargeback management Disputes are handled under the Refund Policy, with Account suspension for pending
chargebacks and closure for abuse.
Tax reporting Taxpayer information is collected where required, and IRS information returns are issued
as required by law.
Digital currency Where offered, wallet addresses and transactions are screened using blockchain analytics
by OnPoint or its payment partners.
10 RESPONSIBLE GAMING
OnPoint is committed to keeping the Platform a safe form of entertainment. Responsible gaming measures
include:
• Player-controlled purchase limits, cool-off periods, and self-exclusion, as described in the Responsible
Gaming Policy;
• The ability for OnPoint to impose limits or close Accounts where there are concerns about a user's
wellbeing;
• Age verification controls and a strict prohibition on use by minors;
• Exclusion of self-excluded users from marketing communications; and
• Prominent display of support resources, including the National Problem Gambling Helpline at
1-800-GAMBLER.
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11 GAME INTEGRITY AND FAIR PLAY
• Game outcomes are determined by random number generation, and game rules and paytables are displayed
within each Game.
• Server-side records are the binding record of all gameplay, transactions, and balances, and a malfunction
voids all affected pays and plays.
• Bots, automation, collusion, multiple Accounts, and exploitation of errors are prohibited and actively
monitored.
• Promotions are subject to published terms, and promotional rewards obtained through abuse are voided.
12 MARKETING AND AFFILIATE STANDARDS
Marketing is a key compliance risk area, and several states extend liability for unlawful sweepstakes to
promoters and affiliates. OnPoint and its affiliate partners must follow these standards:
• Marketing must not target minors, self-excluded individuals, or residents of Restricted Jurisdictions, and
geo-targeting must exclude Restricted Jurisdictions.
• All marketing that references Sweeps Coins or Prizes must include "No Purchase Necessary" and "Void
Where Prohibited" disclosures.
• Marketing must not describe the Platform as real-money gambling, promise winnings, or present Prize
redemption as a source of income.
• Affiliates must comply with OnPoint's marketing guidelines, and non-compliant affiliates are suspended or
terminated.
The Platform and its marketing use consistent sweepstakes terminology:
USE INSTEAD OF
Purchase Gold Coins Deposit, buy chips, or fund an account
Play Bet or wager
Redeem Sweeps Coins for Prizes Withdraw or cash out
Social sweepstakes casino Online casino or real-money casino
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13 CONSUMER PROTECTION AND TRANSPARENCY
OnPoint publishes a complete policy suite that governs the Platform and is available to all users:
DOCUMENT WHAT IT COVERS
Terms and Conditions Eligibility, Restricted Jurisdictions, Virtual Coins, purchases, redemptions,
prohibited conduct, and dispute resolution
Sweepstakes Rules Sweeps Coins, play-through requirements, redemption minimums, and Prize
terms
Alternative Method of Entry Policy All free methods of obtaining Sweeps Coins, including mail-in requirements
Privacy Policy Collection, use, sharing, and protection of personal information, including state
privacy rights
Refund Policy Purchases, limited refund circumstances, and chargebacks
Customer Complaint Policy Complaint submission, handling timelines, escalation, and next steps
Anti-Money Laundering Policy AML and sanctions program, due diligence, monitoring, and reporting
Responsible Gaming Policy Player protection tools and support resources
Complaints are acknowledged within 2 business days, with a target response within 10 business days and a
senior management escalation path, as set out in the Customer Complaint Policy.
14 DATA PROTECTION AND SECURITY
Personal information is handled in accordance with the Privacy Policy. Security measures include TLS
encryption in transit, encryption of sensitive data at rest, role-based access controls, vendor due diligence, and
regular security assessments. Biometric data used for identity verification is subject to specific consent,
retention, and destruction requirements, and OnPoint does not sell personal information for monetary
consideration.
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15 COMPLIANCE GOVERNANCE AND ONGOING REVIEW
FUNCTION RESPONSIBILITY
Members Approve compliance policies, oversee the compliance program, and receive regular
compliance reporting
AML Compliance Officer Day-to-day oversight of KYC, AML, sanctions, monitoring, investigations, reporting, and
training
Outside counsel Review of the sweepstakes model, policy suite, and jurisdictional status as laws change
Policy review All compliance policies reviewed at least annually, and sooner when laws, products, or
risks change
Vendor oversight Due diligence on identity verification, payment, geolocation, and game content providers
Independent testing Periodic testing of the AML program by a qualified independent party
OnPoint cooperates with payment partners, banking institutions, and regulators, and will provide additional
documentation in support of partner due diligence upon request.
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16 CONTACT US
For compliance inquiries, partner due diligence requests, or questions about this document, please contact us
using the subject lines below.
REQUEST TYPE SUBJECT LINE
Payment partner or banking due diligence Partner Due Diligence
Questions about this document or the compliance model Compliance Inquiry
Regulatory or law enforcement inquiries Compliance Request
OnPoint Administration LLC — Compliance
Email: support@onpointcasino.com
Website: OnPointCasino.com
Mailing Address: 8080 N Central Expy, Suite 1700, Dallas, TX 75206
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