Once upon a time, I did some research on this subject, but I don't seem to be able to put my hands on the information at the moment. However, if my memory serves me right, I think what you are considering would still be a violation because they have to make a purchase somewhere to participate in your raffle.
I think in general, you can only get around the rules and have a drawing if it is open to customers and noncustomers and there is nothing they have to do to participate (no required account, nothing to purchase, etc.)
Again, this is just my opinion based on memory, since I don't have the documentation in hand to refer you to.