Lawmakers in Oklahoma and Tennessee are advancing aggressive measures to eliminate the dual-currency sweepstakes model, positioning both states to become the first to officially ban these platforms in 2026.
While Oklahoma and Tennessee are taking different legislative paths, the end goal remains the same: bringing online casino-style games under strict regulatory or criminal control.
Oklahoma: Criminal Felonies and Imprisonment
Oklahoma’s Senate Bill 1589 directly expands the state’s gambling statutes to cover “online casino games”. The bill defines these as any internet-based gambling that simulates traditional games like slot machines by risking a “representative of value”. Crucially, the legislation clarifies:
“A ‘representative of value’ includes any and all currency used as part of a dual‑currency system of payment that allows a person to exchange such currency for any prize, award, cash, or cash equivalent.”
Under this proposal, violations are not taken lightly; they would be treated as Class C2 felonies, carrying fines up to $2,000 and potential imprisonment. The law would hold everyone in the supply chain liable, including geolocation providers, gaming suppliers, and media affiliates. If enacted, the ban will take effect on November 1, 2026.
Tennessee: Immediate Consumer Protection Ban
Tennessee is utilizing the Consumer Protection Act via Senate Bill 2136 to address sweepstakes casinos from a player-safety perspective. This bill declares that the promotion of online sweepstakes games is an offense against public health, safety, and welfare.
The state has already taken a hardline stance. In December 2025, Attorney General Jonathan Skrmetti issued cease-and-desist letters to nearly 40 sweepstakes casinos, successfully forcing many to exit the state. By classifying these operations as “unfair or deceptive acts,” the new legislation provides the Attorney General with permanent authority to investigate and prosecute any remaining operators immediately upon the bill’s passage.
