My client wants to build some sort of gambling app. I said to him Google Play does not allow gambling apps and they will get removed.

I also mentioned that maybe like Facebook Poker, if you include fake currency which would be purchasable with real money maybe it would not be considered gambling application.

Here is his game idea:

I want to make an app that people get on and put money in and raffle money, it's like gampling/raffling . Let's say I raffle 20 bucks and you put in 1dollar/99c to try and win the raffle but only after 20 people have put in the raffle will began. If 20 people don't join within a certain amount of time they get refunded. So 1 dollar plus 20 people=20 dollars I get 10 profit and a lucky winner gets 10. We can set smaller to bigger raffles. It will be a fun addictive app. the whole world will be on it.

So if I implement these changes would this new application still be considered gambling application?

Google play Gambling terms

  • 1
    Can you paste in the relevant section of Google Play's terms of service that prohibit gambling apps? The language there may well be the determining factor. It it may be ambiguous enough that you won't know until you try it and see if Google approves.
    – mikeazo
    Jul 1, 2016 at 15:58
  • 1
    You should probably take into account whether the fake currency can be converted back into real currency or exchanged for merchandise. In other words, if the plan is changed so people buy some kind of fake currency to participate in the raffle, it probably matters what they can do with their winnings. If they can convert the fake currency back into cash then it probably has a similar status to a casino chip, and, as we all know, chip games in casinos are also a form of gambling.
    – phoog
    Jul 1, 2016 at 17:52
  • I have added a link, the description is quite short but it does explain well.
    – Vlad
    Jul 2, 2016 at 16:58

4 Answers 4


The app you describe sounds illegal to me.

Specifically, it sounds like a lottery. According to this site:

[In the state of Ohio]

A lottery includes three things: (1) chance, (2) prize, (3) and consideration. To successfully run a contest or sweepstakes and not an illegal lottery, you must eliminate one of these factors. A contest, for example, eliminates chance and a sweepstakes eliminates consideration (typically an entry fee). You must be careful, however, that you are actually eliminating one of the three factors.

Your idea of substitute currency is making its way through the courts right now. In a case involving the video game Counter-Strike: Global Offensive where players compete for skins which have a real-world positive trade value.

  • Well actually I asked this question just so I make sure I don't do something illegal. Thanks for the advice. Probably will cancel this job offer.
    – Vlad
    Jul 2, 2016 at 17:00

It's really your client that should be asking these questions.

Writing the app is perfectly legal. So you can enter a contract with that client to write the app and deliver it to them, ready to be put on the Google Play store or the App Store (entering a contract needs to be done carefully, obviously). I'd make 100 million percent sure that the contract states clearly that you have zero responsibility if the app is rejected or removed for non-technical reasons, and that the legality of actually selling and running the app is also not your responsibility.

The reason is that I very much suspect that running the app might be illegal, and that the chances of getting it permanently on one of the stores are rather slim. And solving those problems is outside of what a software developer can competently do.

  • "Writing the app is perfectly legal." That's not the legal advice I got when I investigated after being asked to write some libraries to be used by gaming software years ago. Also, see this article. Mar 16, 2021 at 18:53

The google play terms say, in relevant part:

For all other locations, we don't allow content or services that facilitate online gambling, including, but not limited to, online casinos, sports betting and lotteries, and games of skill that offer prizes of cash or other value.

It seems to me that any sort of token or "fake money" which is convertible back into currency or into goods such as a prize would be a "thing of value" and thus such an app would not be accepted by google play (except in the limited set of jurisdictions), whether it was legal or not.

Laws on exactly what gambling is illegal vary widely, and you haven't said what jurisdiction you would be operating in.

As anothe answer said there is nothing illegal about writing such an app, restrictions may well apply to running it, and particularly to charging money or accepting winnings from it. But those will vary depending on the country and state/province. A license might be required.

  • New Your State, for example, makes it unlawful for anyone to "knowingly advance and profit from gambling activity". I don't see why that wouldn't cover intentionally writing an app to be used for gambling. New York State has used that law to go after people who develop and license gambling software. I don't know of them using it to go after anyone who didn't get a cut of the profits, but that doesn't seem to be an element of the offense as far as I can tell. Mar 16, 2021 at 18:58

Not a legal answer but a possible business model.

Parties can agree to bet real money based on fake money. You just charge to host the game. If your game facilitates tracking transactions in a way that make it easy to balance to real money you may attract a set of players willing to a use fee.

I would be similar to a poker room that takes no rake. Players bet with real money. You just charge by the hour for the seat. Poker in Oregon is kind of like this.

  • 1
    If it's not an answer about the law, why post it as one?
    – user4657
    May 7, 2018 at 19:07
  • @Nij Keep on showing the love. A business model that avoids legal issues would be out of scope here?
    – paparazzo
    May 7, 2018 at 19:08
  • Yes, it would be out of scope. This is Law Stack Exchange, not Business Advice Stack Exchange. Even if it was accepted, the question asks something specific - this ignores the request entirely - so it's not an answer regardless.
    – user4657
    May 7, 2018 at 19:10
  • @Nij An attorney would never consult on how to avoid legal issues?
    – paparazzo
    May 7, 2018 at 19:11
  • That's not what this question does, and that's not what you're helping them to do. They're not deciding the mechanism, they're just coding the one they're told to.
    – user4657
    May 7, 2018 at 19:14

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