What each processor lets us do — broken down by the things we actually run (donations, no-purchase-necessary sweepstakes, skill prediction games, top-fundraiser prizes) — and exactly how to verify whether a processor permits them before we integrate.
Being legal is not the same as being allowed by your processor. Our model is lawful: under US law a promotion is only an illegal lottery when prize + chance + consideration all coexist — we remove consideration with a free AMOE (no purchase necessary), and our prediction games are skill, not chance. That makes it a legal sweepstakes/contest.
But that legal analysis does NOT override a processor's acceptable-use policy. Most processors bucket "sweepstakes, contests, games of skill/chance with a prize" under gambling and ban or gate them regardless of legality. So the binding constraint is processor policy, and the only way to a definitive yes is the processor's underwriting/pre-approval.
Bottom line: Stripe is the only processor with an explicit, current US carve-out for charity sweepstakes for fundraising. A few others (Checkout.com, Adyen, PayPal, Finix) can potentially support us but only through pre-approval/underwriting — and for Adyen & Finix the answer flips to "prohibited" if we operate as a platform/marketplace. Helcim bans it outright.
| Processor | Charity donations |
Sweepstakes (free AMOE) |
Skill games w/ prize |
Top-raiser prizes |
Per-event links + webhooks |
Net verdict |
|---|---|---|---|---|---|---|
| Stripe | ✓ allowed | ✓ US carve-out* | ⚠ underwriting* | ⚠ underwriting* | ✓ | #1 — only explicit US carve-out |
| Checkout.com | ⚠ pre-approval + reg. | ⚠ pre-approval | ⚠ pre-approval | ⚠ pre-approval | ✓ | #2 — enterprise underwriting |
| Adyen | ⚠ restricted | ⚠ direct only | ⚠ direct only | ⚠ direct only | ✓ | #3 — direct merchant ONLY (✗ platform) |
| PayPal / Braintree | ✓ | ⚠ prior approval | ⚠ prior approval | ⚠ prior approval | ✓ | High-friction; narrow US approval |
| Finix | ⚠ restricted | ⚠ direct only | ⚠ direct only | ⚠ direct only | ✓ | Direct only (✗ platform/ISV) |
| Helcim | ✓ | ✗ banned | ✗ banned | ✗ banned | ✓ | Avoid — outright ban |
| Square · Mollie · Authorize.Net | ? verify | ? verify | ? verify | ? verify | ✓ (links/webhooks ok) | Sweepstakes stance unverified |
| High-risk specialists (PaymentCloud, Durango, Corepay…) |
? | likely ✓ (their niche) | likely ✓ | likely ✓ | ? verify | Purpose-built but unverified |
✓ allowed permitted (often still with due-diligence) · ⚠ approval allowed only via pre-approval / underwriting / registration · ✗ banned prohibited outright · ? verify not confirmed. *Stripe: the charity-sweepstakes carve-out is explicit; the skill-prediction-prize layer and top-raiser prizes are not auto-blessed by it and must be disclosed to Stripe underwriting under the charity-fundraising category.
Adyen and Finix classify sweepstakes/skill-prizes as Restricted (allowed with conditions) for a single direct merchant — but Prohibited for a platform/marketplace that onboards sub-merchants. If HeroPicks onboards events/charities as sub-merchants, those two drop off the list entirely. This architectural choice must be settled before any underwriting conversation, because it changes the shortlist. (Stripe and Checkout.com gate platform models behind their own approval, not an outright ban.)
The only processor with an explicit US carve-out. Under Restricted → "Crowdfunding and fundraising":
"Charity sweepstakes and raffles for the explicit purpose of fundraising (Supported in … the United States)" and "Fundraising … offering a reward in return for donation."
But its separate Prohibited bucket bans "payments of an entry or player fee that promise … a prize," "sports forecasting or odds-making with a … prize," and "games of chance … sweepstakes and contests … with a … prize."
Path: Restricted = additional due diligence / prior approval. A true free-AMOE, no-entry-fee model avoids the entry-fee prohibition — but present the prediction-game + top-raiser prize layer to underwriting under the charity-fundraising category; don't assume the carve-out auto-covers them.
The word "sweepstakes" never appears — so it falls under the nearest bucket. Lottery/raffle/betting (MCC 7995) = declined; "Game of Skill & Fantasy Sports" (MCC 7994) = pre-approval; charity (MCC 8398) = pre-approval and:
"Appropriate registration must be in place." Platform merchants in restricted sectors are "prohibited, unless prior written consent to onboard … is obtained from Checkout.com."
Path: enterprise underwriting / prior written consent. Frame as charity fundraising + skill prediction — never as a raffle/lottery (those are declined).
Two-column policy (Merchant | Platform/Partner). "Legal gambling or Game of Skill … with prizes of material value" = Restricted (Merchant) | Prohibited (Platform/Partner); "Any type of US-based gambling" = Prohibited for both; nonprofit/crowdfunding = Restricted for both.
Path: usable only as a direct merchant via written waiver (revocable at Adyen's discretion). Prohibited under the platform model. Does not distinguish AMOE from gambling.
Groups it all in one approval-gated bucket:
"Games of chance and games of skill — includes any activity with an entry fee and a prize, regardless of whether the outcome is determined by chance or skill," and lottery clause covers "raffle, drawing, sweepstake … contest involving the distribution of prizes."
Path: prior PayPal approval (not a permanent ban). A free-AMOE/no-entry-fee model sidesteps the entry-fee clause, but the sweepstake/contest clause + pre-approval still apply; US approval is narrow.
"Sweepstakes" = Restricted (Direct Merchant) | Prohibited (Platform/ISV) — same as gambling, fantasy sports, and forecasting. No AMOE/skill carve-out. Restricted = enhanced due diligence.
Path: only as a single direct merchant. Prohibited for the platform/ISV channel.
Bans the whole model with no carve-out: "games of chance … sweepstakes and contests … with a … prize," "games of skill … competitions … with a … prize," and "entry or player fee that promises … a prize; prize giveaways."
Path: none. Definitive ban — do not shortlist.
Every processor exposes the same three-layer structure. Work it in order, then confirm with a human:
sweepstakes, contest, game of chance, game of skill, lottery, raffle, prize giveaway, entry fee, odds-making / forecasting, consideration, fundraising, charity / nonprofit, pre-approval.7995 gambling/lottery (usually declined) · 7994 game of skill / fantasy (usually pre-approval) · 8398 charitable / social-service fundraising (usually pre-approval + registration).A separate legal requirement, additive to processor approval. Prizes over $5,000 generally require registration + bonding in NY and FL; RI for retail-tied prizes over $500. A processor approving us does not satisfy a state filing, and a state filing does not make a prohibiting processor allow it. (Confirm exact current thresholds with counsel.)
Stripe, Checkout.com, Adyen, PayPal/Braintree, and Finix all expose REST hosted-checkout/payment-link creation + signed webhooks that run fine on Cloudflare Workers. The binding selection constraint here is acceptable-use policy, not technical fit.
#1 Stripe — the only processor with an explicit US charity-sweepstakes carve-out; pursue full-model approval through its underwriting (disclose the prediction-game + top-raiser prize layer).
#2 Checkout.com — viable via enterprise pre-approval + registration; frame strictly as charity fundraising + skill prediction.
#3 Adyen — only if we stay a direct merchant (prohibited as a platform); never US gambling framing.
Backstop: a high-risk/sweepstakes-specialist processor (PaymentCloud, Durango, Corepay) is purpose-built for exactly this, but needs a verification pass on API + terms.
Avoid: Helcim (outright ban), and Finix/Adyen as a platform.
Whatever we pick, confirm in writing via underwriting, and pin our direct-vs-platform model first.
Square, Mollie, and Authorize.Net have good link/webhook APIs but their sweepstakes stance was not verified — check before relying on them. The high-risk specialists (PaymentCloud/Durango/Corepay) are named for the niche but produced no verified primary-source policy here — they need their own pass. Stripe's carve-out names charity sweepstakes/raffles specifically; the prediction-game prize layer and top-raiser prizes are not auto-covered and must clear underwriting. State-registration dollar thresholds are from sweepstakes-law guidance, not statute-verified here. Re-verify all policy language against each provider's current docs before integrating.
Stripe restricted-businesses + nonprofit FAQ (stripe.com/legal/restricted-businesses) · PayPal gambling-prohibition + Acceptable Use Policy (paypal.com/us/cshelp, paypal.com/us/legalhub) · Adyen prohibited/restricted list (adyen.com/legal/list-restricted-prohibited) · Helcim AUP (legal.helcim.com/us/acceptable-use-policy) · Checkout.com platform AUP (checkout.com/legal/unregulated-platform-aup) · Finix prohibited/restricted businesses (finix.com/terms-and-policies) · Sweepstakes-law / AMOE / registration (Holland & Knight; ussweeps.com; kleinmoynihan.com).