Gaming Authorization & Social Sweepstakes Compliance Model

1. Company Identification

ONPOINT ADMINISTRATION LLC (“OnPoint,” “Company,” “We,” “Us”) operates a promotional social gaming platform that complies with all applicable U.S. federal and state laws governing sweepstakes promotions.

2. Platform Classification

OnPoint Casino operates as a Social Sweepstakes Gaming Platform, NOT as a gambling or real-money wagering service.

Key Characteristics:

• No real-money gambling
• No wagering of cash for cash prizes
• No consideration required to enter
• Promotional sweepstakes model only
• Prizes awarded through chance-based sweepstakes mechanics

OnPoint Casino does not operate a casino, sportsbook, lottery, or gambling operation under U.S. law.

3. Sweepstakes Legal Framework

OnPoint Casino's promotions are structured to comply with the three required elements of lawful sweepstakes under U.S. law:

3.1 Prize

Participants may receive promotional prizes, including but not limited to:

• Digital credits
• Virtual currency
• Promotional rewards
• Redeemable prize equivalents (where permitted)

3.2 Chance

Winners are determined by chance through randomized, pre-disclosed methods.

3.3 No Consideration

No purchase or payment is required to enter or win. A free alternative method of entry (AMOE) is always available and clearly disclosed.

Because one of the three gambling elements (consideration) is removed, the platform does not constitute gambling.

4. Virtual Currency Structure

OnPoint Casino utilizes dual-currency social gaming mechanics, which may include:

4.1 Gold Coins (GC)

• Used solely for entertainment
• Have no cash value
• Cannot be redeemed for prizes
• Used for social gameplay only

4.2 Sweepstakes Coins / Promotional Credits (SC)

• Acquired via free methods (AMOE, promotions, bonuses)
• Used to enter sweepstakes games
• May be redeemable for prizes subject to verification and eligibility
• Not sold as gambling consideration

Virtual currencies do not represent real money, deposits, or wagers.

5. Free Alternative Method of Entry (AMOE)

OnPoint Casino provides a free method of participation, which may include:

• Mail-in requests
• Online request forms
• Promotional entry opportunities

AMOE entries receive equal odds of winning as any other entry. AMOE instructions are publicly available and accessible at all times.

6. Age & Eligibility Requirements

• Minimum age: 18 years old (or higher where required by state law)
• Users must be legal residents of jurisdictions where social sweepstakes are permitted
• Employees, officers, and affiliates of ONPOINT ADMINISTRATION LLC may be excluded where required

OnPoint Casino reserves the right to restrict access in jurisdictions where sweepstakes promotions are prohibited.

7. Geographic & Jurisdictional Compliance

OnPoint Casino actively monitors U.S. state and federal regulations and restricts participation where necessary, including but not limited to:

• States that prohibit social sweepstakes models
• Jurisdictions requiring additional licensing
• International jurisdictions where sweepstakes are restricted

Geo-blocking and account controls may be used to ensure compliance.

8. Partner & Vendor Compliance (A–Z)

All partners, vendors, service providers, and affiliates (“Partners”) engaged by ONPOINT ADMINISTRATION LLC must comply with this compliance model, including but not limited to:

8.1 Game Developers

• Provide skill-neutral, chance-based games
• No real-money wagering mechanics
• Certified RNG or equivalent fairness controls

8.2 Payment & Wallet Providers

• Process only promotional purchases
• No gambling-coded transactions
• Clear separation between entertainment purchases and sweepstakes entries

8.3 Marketing & Affiliate Partners

• Must not represent the platform as gambling
• Must disclose “No Purchase Necessary”
• Must comply with FTC advertising guidelines

8.4 Technology & Infrastructure Providers

• Maintain secure systems
• Support compliance controls
• Protect user data under applicable privacy laws

8.5 Prize Fulfillment Partners

• Verify winners
• Ensure lawful prize delivery
• Maintain audit trails

All partners are subject to ongoing compliance review and termination for non-compliance.

9. Anti-Money Laundering (AML) & Fraud Prevention

Although not classified as a gambling operator, OnPoint Casino maintains internal controls to prevent:

• Fraudulent activity
• Multiple account abuse
• Bonus exploitation
• Identity misuse

These controls may include:

• Identity verification
• Transaction monitoring
• Account activity reviews

10. Responsible Play & User Protection

OnPoint Casino promotes responsible social gaming by offering:

• Account limits
• Self-exclusion tools
• Clear disclosures that the platform is for entertainment only

The platform does not promote financial gain or gambling behavior.

11. No Real-Money Gambling Disclaimer

OnPoint Casino expressly states:

• No real money is wagered
• No gambling license is required
• No betting against the house
• No odds manipulation
• No casino-style cash wagering

All gameplay is promotional, social, and entertainment-based.

12. Regulatory Position Statement

ONPOINT ADMINISTRATION LLC operates under applicable U.S. sweepstakes and promotional marketing laws and does not require a gambling license.

This model is structured to comply with:

• Federal Trade Commission (FTC) regulations
• State promotional sweepstakes laws
• Consumer protection statutes

13. Modifications & Updates

OnPoint Casino reserves the right to modify this compliance model to reflect:

• Regulatory updates
• Platform changes
• Partner requirements

The most current version will always be published on the website.

14. Contact Information

For compliance inquiries:

ONPOINT ADMINISTRATION LLC
Compliance Department
8 The Green, Ste A
Dover, DE 19901
United States
support@onpointcasino.com