Our bank has a regular incentive program where employees are compensated for referrals to our Wealth Management group. The Wealth Management group now wants to run a promotion where on top of the regular incentive pay, the employee will also be entered into a drawing for an additional cash prize. The employee gets an entry for each qualified referral, so the more referrals they make, the better their chance of winning. At the end of the promotion one employee will win the additional cash prize.

I have seen some posts on here that seem to say that this just sounds like an incentive program, but I'm worried it could be considered a lottery. Has anyone else done something like this?

It is incentive compensation and not a lottery.