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investigation · 2026-10-03 · terms and rules dated October 1, Maryland still absent

Modo's rules dropped Maryland six weeks after the ban bills died

ARB Gaming's Modo.us named Maryland in every exclusion list we could find from September 2024 through January 2026. On May 29, 2026, the state left both its Terms of Use and its Sweepstakes Rules. The versions dated October 1, 2026 still leave it out and add Oklahoma, and Modo's support center now lists Maryland among the states where Sweepstakes Coins can be played. Maryland's regulator lists cease-and-desist letters to High 5, McLuck, Pulsz, VGW and Stake.us, but none to Modo, on a list it says is not comprehensive. The operator has not said why the lists changed.

By Kyle Lewis, Editor

Published October 3, 2026. Every claim below cites a document we opened; each was retrieved October 3 unless the list at the end gives an earlier date.

Disclosure: this site's publisher, Luck Incorporated LLC, operates Chance Infinite, a free-entry sweepstakes app that competes for some of the same players Modo courts.

What the documents changed on May 29

The plain answer: Modo's own documents removed Maryland from their exclusion lists on May 29, 2026, and the versions we opened on October 3, 2026 have not put it back. Its Rules name the sponsor as "ARB Gaming, LLC d/b/a Modo.us" and describe two currencies, Gold Coins and Sweepstakes Coins. Its Terms of Use "updated as of January 5, 2026" list seventeen "GC Only States" where a user agrees not to play "with Sweepstakes Coins": Maryland, Pennsylvania and Rhode Island among them. The Terms "updated as of May 29, 2026" list sixteen: those three are gone, Indiana and Maine added. The Terms "updated as of August 20, 2026" carried the same sixteen.

The live Terms, "updated as of October 1, 2026", list seventeen GC Only States. Maryland, Pennsylvania and Rhode Island are still absent; the one addition is Oklahoma. Compared word by word with the August 20 copy, the other changes are the date, a new Wallet section, corrected section cross-references and one spelling fix.

The Sweepstakes Official Rules moved in step. A copy captured May 5, 2026, with no date line, excludes "anyone entering while located in the following restricted states" and names the same seventeen as the January Terms. The Rules "Last Updated: May 29, 2026" named sixteen, without those three. The live Rules, "Last Updated: October 1, 2026", name seventeen: the same states as the October 1 Terms, Oklahoma included and Maryland not.

The exclusion is old. Modo's Terms and Conditions of September 10, 2024 put Maryland in an "Excluded Territory"; the Terms of December 1, 2025 listed it among the "GC Only States". In secondary reporting, the trade site Sweepsy said on October 30, 2025 that Modo ran "a full platform shutdown in its current excluded states," Maryland listed.

The Terms and Rules do not say whether Sweeps Coins are sold, played or redeemed from Maryland today, but Modo's support page "Is SC-play available in my state?", retrieved October 3, 2026, lists Maryland among the states that "can play with both GC and SC", and lists Rhode Island, which the October 1 Terms omit, as GC-only. One incorporated document points the other way: Modo's privacy policy, "Last updated 18 January 2026" and still the version served on October 3, 2026, says it does "not permit users in the following states to sign up for an ARB Gaming account", a list of thirteen that includes Maryland, Pennsylvania and Rhode Island but not Oklahoma. The operator has not published an explanation for the change; this article will be updated if one is provided.

The bills died first

Modo did not move against a live ban. In the General Assembly's 2026 bill list we found four ban bills, two House bills and their Senate cross-files; all four ended in the Senate Budget and Taxation Committee. HB 1226 passed the House on March 23, 2026, 135 to 1, and its status still reads "In the Senate - Hearing 3/31 at 1:00 p.m." HB 295, the regulator's own bill, passed March 20, 105 to 24, and was set for a hearing April 1. The cross-files never left the committee: SB 652, HB 1226's cross-file, stopped at "Hearing 3/11 at 1:00 p.m.", and SB 112, HB 295's, at "Hearing 1/28 at 1:00 p.m." None went to the Governor.

The Department of Legislative Services' 2026 calendar marks the 90th day, adjournment "SINE DIE", as Monday, April 13. Modo's Terms and Rules dropped Maryland forty-six days later. On October 3, 2026 all four bill pages showed the same last actions, and we found no 2027 Maryland bill (the site returned errors for 2027 bill pages). Our crackdown timeline lists Maryland's bills as failed.

Oklahoma went the other way

Oklahoma, the one state Modo added on October 1, enacted SB 1589 over the Governor's veto: the bill history records overrides on May 14, 2026, 34 to 10 in the Senate and 68 to 19 in the House. Under the enrolled text, "Representative of value" in the state's gambling statute includes "any and all currency used as part of a dual-currency system of payment that allows a person to exchange such currency for any prize, award, cash, or cash equivalent," and the act "shall become effective November 1, 2026."

Read together, the records show Modo dropping a state where ban bills failed and adding one where a dual-currency amendment passed. That is a sequence of dates, not a stated reason; Modo has not published an explanation for either change.

The regulator's page, and the peers on its list

The Maryland Lottery and Gaming Control Agency keeps a page on which forms of online gaming are lawful in the state. Beyond licensed sports wagering and fantasy, it says: "No other forms of real-money online/mobile gaming or wagering are operating legally in Maryland." Below it, a list of cease-and-desist letters: 96 linked when we re-opened the page on October 3, 2026, the same letters as in the September 5 capture. On it, all but High 5 profiled on our casinos page: McLuck and Stake.us, letters dated May 7, 2024; VGW, for Chumba Casino and Luckyland Slots, March 12, 2025, with a November 2025 letter for each; Yellow Social Interactive (Pulsz), June 3, 2025; High Entertainment (High 5 Casino), March 18, 2025. The page dates only the VGW entries; the rest are the letters' own dates. ARB Gaming and Modo are not on the list.

We are not a regulator and we do not claim any law is being broken. The agency limits what its list means: it "only represents the operators to which Maryland Lottery and Gaming has issued cease-and-desist letters", and is not comprehensive. Absence is not a finding.

Operators that did receive letters keep Maryland in their lists. Pulsz's Terms of Use, version 5.2 of September 1, 2026, name fourteen "Restricted Territories", Maryland among them. High 5 Casino's Sweepstakes Official Rules, version 43.0 of June 26, 2026, exclude twenty-one states, Maryland included.

Three smaller things in the same files

First, age. The Terms of October 1, 2026, like those of August 20, have the user affirm "You are over 18 years of age"; the Terms of May 29 said 21, and the Rules of October 1, which the Terms incorporate, still require entrants "twenty one (21) years of age or older". Modo's support page "Can anyone play at Modo?", retrieved October 3, 2026, explains the split as tiers: "Players 18 to 20 can enjoy Gold Coin (GC) games and Modo Boxes", while Sweeps Coins play requires 21.

Second, a wallet. New sections 12.13 to 12.19 of the October 1 Terms let eligible users add funds to a "Wallet" for "the sole purpose of purchasing Gold Coin packages and/or Modo® Box openings"; the funds "are not a deposit account", must be spent once before any withdrawal, and carry a $6.00 minimum withdrawal. The Rules say Sweepstakes Coins "cannot be purchased under any circumstances", Wallet funds included.

Third, Minnesota. A proposed class action against ARB Gaming, LLC (D. Minn. No. 0:26-cv-03396), filed July 23, 2026, alleges that Modo's casino-style games are gambling prohibited by Minnesota law. The allegations are unproven and the case is pending. The docket mirrored by CourtListener, queried October 3, shows no answer. Its later records are orders on counsel admissions, on extensions of time (September 9 and 24) and of recusal (September 23); the mirror is incomplete, with nine records although the recusal is entry 24. The October 1 Terms do not list Minnesota. ARB Gaming's Terms give arbinteractive.com addresses for copyright notices and disputes, and ARB Interactive's website presents Modo and Publishers Clearing House as its products; it bought PCH's assets, as our PCH article records.

What a player should do with this

If you are in Maryland, read all three: Rules, Terms, privacy policy. Two no longer exclude you, and Modo's support page lists Maryland for Sweepstakes Coins play; the privacy policy still says you cannot open an account. Modo has not said how these fit together; the Rules still carry the line "Void where prohibited by law", and the age split matters if you are under 21. In Oklahoma, both October 1 documents now exclude Sweepstakes Coins play, but Modo's Oklahoma support page, retrieved October 3, 2026, says play and "SC redemptions stay available in Oklahoma until November 1, 2026", and that mail-in requests postmarked after October 1 are not accepted. If you hold a balance there, confirm with Modo at [email protected]. Never pay a fee, wire or gift card to someone who contacts you unprompted about a prize (see prize-claim scams). This site does not rank dual-currency casinos (see our exclusion explainer); how to read official rules covers eligibility clauses. Update, October 16, 2026: our scored rankings still leave out sweepstakes casinos, but the app database page now shows the editor's casino picks and lists that include casinos that pay us a commission.

Common questions

Is Modo available in Maryland?

Maryland has been missing from the Modo Terms of Use and Sweepstakes Rules since the versions dated May 29, 2026, and the versions dated October 1, 2026 still do not list it among the states excluded from Sweeps Coins play. The Modo privacy policy, dated January 18, 2026, still says users in Maryland may not sign up for an account. A Modo support page retrieved October 3, 2026 lists Maryland among the states that can play with both Gold Coins and Sweepstakes Coins. The operator has not explained the change.

Did Maryland ban sweepstakes casinos in 2026?

No 2026 bill became law. HB 1226 passed the House 135 to 1 on March 23, 2026 and HB 295 passed 105 to 24 on March 20; both died in the Senate Budget and Taxation Committee, as did their cross-files, SB 652 and SB 112. The session adjourned sine die April 13, 2026, and none of the four reached the Governor.

Is Modo on the Maryland cease-and-desist list?

Not as of October 3, 2026. The Maryland Lottery and Gaming Control Agency list of 96 cease-and-desist letters includes High 5 Casino, McLuck, Stake.us, Chumba Casino and Luckyland Slots from VGW, and Pulsz, but no letter to ARB Gaming or Modo. The agency says the list is not comprehensive.

Documents we opened

Retrieved October 3, 2026 unless marked otherwise; archived links are Wayback captures.

Related: Modo daily login bonus and redemption facts · The crackdown timeline · The casinos, by name · PCH now sells entries