Would the following be considered a lottery or would it be ok? As a promotion of our Pop Money, we set up a wheel with variable dollar amounts that customers spin. To spin the wheel the customer must donate $1 that we donate to a charity. All the amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via Pop Money. We set a certain number of spins and it is done on a first come first serve basis.
Our local Chamber of Commerce is giving away raffle tickets for a chance to win a shopping spree downtown for the holidays. They have asked the bank to offer tickets to our customers. My question is, may we offer multiple tickets to customers if they were to sign up for certain services? For example: Make a deposit worth 1 ticket, sign up for online banking and receive 2. Another example would be to apply for a car loan and receive 1 ticket, qualify and finance with us pays 5 tickets.
I'm looking for guidance on filing SARs and/or reporting activity on lottery accounts owned by businesses that aren't exclusively lottery outlets. If a SAR is filed, what activity characterization is selected? Do we have an obligation to report the misuse to the lottery commission?