We believe that the raffle would technically be considered a lottery, which is prohibited under federal banking law and under Illinois criminal law. There is no exception under the lottery rules for games that are held for employees only. 

• The National Bank Act prohibits national banks from dealing in any lottery, defined as an arrangement in which participants “advance money or credit to another in exchange for the possibility or expectation that one or more but not all of the participants (the ‘winners’) will receive by reason of their advances more than the amounts they have advanced.” 12 USC 25a(c)(2). 

• And the Illinois Criminal Code prohibits all persons from gambling, including setting up a lottery, selling or offering lottery tickets, printing lottery tickets, or advertising a lottery. 720 ILCS 5/28-1(a). The code defines lotteries as “any scheme or procedure whereby one or more prizes are distributed by chance among persons who have paid or promised consideration for a chance to win such prizes . . . .” 720 ILCS 5/28-2(b).

• While there are several exceptions to the prohibition on lotteries, we believe that only one exception could apply to a bank: the exception for drawings in which “money or other things of value can be won but no payment or purchase is required to participate.” 720 ILCS 5/28-1(b)(13).

• Another exception is for raffles conducted under the Raffles Act; however, because raffles by definition involve payment of consideration for a chance to win, any raffle would violate the federal prohibition on bank participation in lotteries. See Raffles Act definitions, 230 ILCS 15/1.