04 November 2026
Twenty U.S. states have taken formal enforcement actions against unlicensed online casinos and dual-currency “sweepstakes” operators since 2023. Yet a new investigation shows specific brands still accepting or inviting U.S. residents, even in states that have banned their games or warned them to desist.
This month, Gambling Related Harm released the most comprehensive report yet tying regulatory actions to public-facing eligibility policies. The "Banned but Open" investigation found that nearly 30% of the brands that have been warned or banned actively appear in front of invited customers from some of these states, and continue to tout that eligibility in their terms.
Florida, Kentucky, and Maryland Regulators Say No, Chumba and LuckyLand Say Go
In August 2023, Florida's Attorney General took a landmark step: a lawsuit against multi-brand giant VGW for illegal gambling. The state alleged that Chumba Casino, LuckyLand, and Global Poker offered real-money gambling to Florida residents, despite Florida being excluded from their state gambling laws.
A coalition of regulators across the U.S. has explicitly blacklisted some of the most well-known brands in dual-currency games, including Chumba and LuckyLand. Maryland issued a cease-and-desist notice eleven months ago when a brand allegedly continued to offer poker and casino games there. As of October 30, 2023, the Gambling Related Harm investigation shows that Chumba and LuckyLand were still explicitly eligible to most Maryland residents under the operators' official terms and site architecture.
The lawsuits in Florida and Kentucky are still pending, highlighting the state of regulatory action against illegal offshore gambling.
Regulators Can't Catch Up
The reach of online casino operators often exceeds regulators' ability to stop them. A Gambling Compliance report notes that the state of Michigan has sent over 30 cease-and-desist letters to offshore casinos, but none of them has a reason to honor them. These sites operate in jurisdictions outside of Michigan's control.
That's not even a new fact. The specifics are in a 2023 Gambling Compliance piece saying that regulators had been warning offshore operators for years, with no real change in behavior.
Blacklists Don't Work
The "Big 3" online casino blacklist compilers – WSN, American Casino Guide, and USGambling – all include multiple offshore casinos in their U.S. "blacklisted" groups. These are United States-facing sites that, despite subsequent cease-and-desist orders, accept U.S. deposits and continue to operate, as they recognize they are not legally bound to comply.
Where do we go from here?
The movement for tighter regulations against dual-currency gambling and offshore casino sites is unmistakable. Gambling Related Harm's investigation reflects expert consensus that the government must do more to protect U.S. customers. A Congressional committee hosted US Rep. Tony Cárdenas recently, decrying casino-affiliated lead generation practices.
Among the report's recommendations are increased cross-state coordination to stop the flow of customer data to offshore casinos. The authors also call for increased fines, criminal penalties, and an early warning system to notify customers of problem sites. Laura Krafchik, managing attorney at Gambling Related Harm, put it this way: "We're witnessing the Wild West of online gambling, a sector that regulators can't keep up with, no matter how fine-toothed their comb."
This is not an academic critique. Operators' real impacts demand a closer look at the consequences of this regulatory gap. When a state has banned something a company already offers, does the company stop offering it? Is there any other kind of civil liability? Whose responsibility is this?
The "Banned but Open" report does not conclude an outright regulatory failure or industry sabotage. Its goal is to quantify a significant information gap, underscoring the need for closer alignment of policies and enforcement.
The real losers here are American gamblers who don't know any better and deposit money into blacklisted companies. But they only lose as much as everyday players spend on mid-tier slot games. The offshore platforms have had no trouble operating, despite fines and legal action, taking bets.
What it costs them is no existential threat. The challenge comes in demonstrating what real harm looks like.
The financial impact pales in comparison to the potential costs of legal action and revenue loss for operators like VGW. Significant portions of a company's income can be affected by regulatory actions. A 2023 article described how New York's actions cost the company $8 million, but allowed them to continue operating unlicensed games. And that was in 2023. The current lawsuits and offshore platforms you can bet on? They represent an ongoing challenge.
We will see what regulators do next, as this follows the first substantive legal actions from affected states.