Lucky Draws, Raffles and Prize Promotions: When They Need a License

What a lucky draw license covers

A lucky draw license is the permission a regulator gives you to run a game where entrants pay something for a chance to win a prize decided by chance. That covers the obvious cases: charity raffles, fundraising draws, trade promotion lotteries where a purchase is required, and prize promotions where the entry fee is baked into the price of a product.

The line that matters is payment. If entrants pay nothing and the prize is small, most regulators treat the promotion as marketing. If entrants pay, or the prize is cash or high value, you are usually in licensing territory.

Macau shows how formal this can get. The territory's gaming regulator publishes an application form specifically for raffles, and it also licenses individual games of fortune by name. Dragon-Phoenix was permitted for operation as a game of fortune⁶, Casino War was approved as a licensed game of luck⁷, and Fortune 8 was approved for operation by casino concessionaires⁸. That is the same regulatory machinery that a charity draw plugs into.

Licensing also extends to online operators. In the Philippines, PAGCOR keeps a public register of accredited gaming system administrators and their registered domain names, and that register includes entries such as luckygame.ph and luckyclub.ph⁹. If you are running a promotional game online in a licensed market, your domain can end up on a list like that.

For a wider view of how these rules sit alongside casino and betting law, see Gambling Laws in Asia: What Is Legal in 12 Jurisdictions.

Macau charity lucky draw: a worked example

The clearest worked example of a licensed charity draw in Asia is the Macau charity lucky draw documented in the regulator's own application form. It is worth walking through because it shows exactly what a licensed draw looks like on paper.

The activity was open to all Macau residents¹.

The mechanics were set out in advance:

• The draw took place on March 15, 2024, starting at 17:00¹.
• The draw was made by computer program at a square in Macau¹.
• Three reserve winners were named in case a winner could not be contacted¹.
• The winners list was published on April 1, 2024¹.

Two details stand out for anyone planning something similar. First, the form asks whether one person can win multiple times, and the answer recorded is yes¹. There is no rule capping each entrant at a single prize. Second, the reserve mechanism is built in from the start, with three named reserves¹. If you are organizing a draw, that is the practical answer to the question of what happens when a winner cannot be reached: you plan for it before the draw, not after.

The MOP 10,000 ticket price is the part that separates this from an ordinary charity raffle. At that price, the draw is a fundraising instrument aimed at a small number of high-value participants, not a street-level raffle. The licensing logic is the same either way, but the scale changes what the regulator wants to see.

Ticket sales and draw mechanics: dates, prices and winner selection

Across Asia, the practical details of a licensed draw follow a similar pattern: a defined sales window, a fixed draw time, a published results date, and a claim deadline.

Singapore Sweep is a useful comparison. Tickets may be purchased from the end of the previous draw until half an hour before the draw². Sales for each draw begin after the previous draw takes place on the first Wednesday of each month¹⁰. Tickets are sold at betting outlets, authorized retailers and their appointed vendors, though some retailers offer only Quick Pick and 100 Numbers entries, and appointed vendors may sell only pre-printed Quick Pick tickets².

China's Super Lotto runs three draws a week, on Monday, Wednesday and Saturday⁵. The draw time is 21:25¹¹. Winners must claim within 60 natural days from the draw date at a designated location, and unclaimed prizes are treated as forfeited, with the money going to the lottery public welfare fund¹².

Japan's number-selection lotteries handle payment differently. Prizes of JPY 10,000 or more are in principle transferred automatically to your registered account within about one week from the next business day after the draw¹³. You do not have to go and collect.

Vietnam's rules focus on the physical ticket. Under Article 31 of Circular 75/2013/TT-BTC, a ticket presented for prize payment must remain intact, at its original size, not torn apart, not patched, not erased and not altered, and it must be within the prize claim period¹⁴. If you fold, tape or laminate a winning ticket, you can lose the prize.

Vietlott adds a proxy rule for winners who genuinely cannot attend. A winner who cannot claim in person for objective reasons such as illness or long business trips may authorize a legal representative, and the authorization must be in writing and confirmed by the commune, ward or town government where the winner resides¹⁵.

For a fuller picture of which draws are legal where, see Which Lotteries Are Legal in Asia?.

How Japan's WINNER, BIG, toto and boat race promotions work

Japan separates its public lotteries from its sports prediction games, and the purchase mechanics differ in ways that catch first-timers out.

The WINNER prediction lottery is the clearest example. Buying at a lottery shop requires you to make a purchase reservation on the official site in advance and issue a QR code¹⁶. This is not optional. WINNER differs from BIG, toto and DUNK in that even when you use a lottery counter or a convenience store, you must register your prediction and issue a QR or bar code on the official site beforehand¹⁷. For competition prediction tickets, you can buy up to 10 minutes before the match starts, and sales hours may change¹⁸. No ticket is issued for the competition prediction lottery bought through convenience store payment¹⁸.

For BIG, the sales cutoff time can change from draw round to draw round, and the current time is listed with the information for each round¹⁹.

There is also a refund mechanism worth knowing about. WINNER operates on a special refund system, which means refunds are possible under certain conditions even if you do not win²⁰.

Promotional draws attached to racing work on a different basis. At a year-end fan appreciation day lottery, you got one lottery entry for every JPY 2,000 of boat tickets bought on the day before the draw was confirmed, up to five entries at once²¹. That is a trade promotion lottery in practice: buy the product, get an entry, no separate ticket price.

For the wider picture on what is legal to bet on in Japan, see Can I Gamble in Japan?.

Prize gaming clubs in Vietnam: the Sheraton Nha Trang raid

Vietnam draws a hard line between licensed prize gaming clubs for foreigners and everything else. Most forms of gambling are prohibited, with limited exceptions such as state-run lotteries and licensed casinos for eligible patrons²².

Prize gaming clubs sit inside that exception, but only for foreign passport holders. King Club, on the first floor of the Pullman Hanoi Hotel at 40 Cát Linh Street, was legally licensed to operate prize-winning electronic games for foreigners only²³. Vietnamese gamblers have been caught disguising themselves as foreigners to play illegally at the Pullman Hotel²³.

The practical lesson for a visitor is straightforward. A prize gaming club being present in a hotel does not mean you can play there. The license is tied to the venue, the game type and the passport you hold. If you are a Vietnamese citizen, walking into a foreigners-only club is the exact fact pattern that gets people detained.

Vietnamese locals do have a narrow casino option. The government allowed Vietnamese locals to gamble at two locations under a three-year pilot scheme, the first in Vân Đồn and the other on Phú Quốc²⁴. That pilot is separate from the prize gaming club licenses.

Police also pursue online betting rings, and prosecutions of players and organizers are routine. If you are considering any form of betting in Vietnam, the practical position is that only state-run lotteries and licensed venues are open to you, and the venue's license tells you who may play²².

For the country-level detail, see Can I Gamble in Vietnam?.

What this means if you are running a promotion

If you are organizing a draw rather than entering one, the practical checklist looks like this.

• Decide whether entrants pay. If they do, assume you need a license or class license unless a regulator tells you otherwise.
• Fix the sales window and the draw date in advance, and publish both. The Macau example ran sales for a month and drew two weeks later¹.
• Name reserve winners before the draw. Three reserves was the Macau figure¹.
• Publish the winners list on a stated date. Macau published on April 1, 2024¹.
• Check whether multiple wins are allowed and state it. Macau allows them¹.
• If the draw is online, expect your domain to be registered with the regulator, as PAGCOR does in the Philippines⁹.

If you are entering rather than running a draw, the checklist is shorter. Keep your ticket intact and unaltered¹⁴. Claim within the deadline, which is 60 natural days for China's Super Lotto¹². If you cannot attend in person in Vietnam, get a written authorization confirmed by your local commune or ward government¹⁵. And if you are buying a Japanese prediction ticket, register online first¹⁶.

For the rules on who may enter a casino or gaming venue at all, see Legal Gambling Age in Asia by Jurisdiction and Game and Which Asian Casinos Bar Local Citizens?.