Without the full rules, then it is hard to say, but if consumers cannot enter the drawing without having the card or without making a purchase, this is a lottery and not a sweepstakes. You also need to check your State's sweepstakes laws to make sure you comply with those requirements as some of those are pretty tough, especially with a $10,000 grand prize. The employee part is not a problem, that is an incentive program.
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com