The term "lottery" includes any arrangement whereby three or more persons advance money or credit to another in exchange for the possibility...

If we want to increase POS transactions and advertise we will randomly choose which POS transactions we will "pay" for our customers during the months of November and December.

Since we are not requiring any type of advancement or credit, it's not considered a lottery, correct?

Someone needs to have an account and a debit card at your Bank to be eligible. They also need to make a POS purchase in order to qualify. How are they not advancing something of value?

I agree. Is there a way to make this right?

I've got an alternative. Thanks for confirming my thought that this was a lottery.