Designing a Compliant Fan Engagement Campaign in E-Sports: A CS2 Championship – Case Study

Overview

A leading crypto project engaged Aurum to design a compliant framework for a promotional campaign supporting a major international e-sports championship in Counter-Strike 2. The campaign allows users to receive tokens representing their chosen teams. At the conclusion of the event, users holding tokens of the winning team receive a proportionate share of the prize pool.

The concept blended fan engagement, token distribution, and competitive reward mechanics — but also raised regulatory concerns, particularly around gambling, financial promotion of crypto assets, and compliance with digital platform policies. Our objective was to enable the campaign to proceed without breaching promotion regulations, falling into gambling regulation, or being treated as an unauthorised promotion of crypto assets.

Core Challenges

• Avoiding gambling classification: The reward structure tied to match outcomes risked falling under betting or gambling regulation.
• Preventing unauthorised financial promotion: Token-based campaigns can trigger securities, investment, or financial promotion rules if not carefully structured.
• Navigating multi-jurisdictional laws: The campaign was set to run across multiple regions, each with distinct rules around gambling, advertising, and crypto-assets.
• Platform compliance: Social media and e-sports platforms often prohibit or restrict crypto-related promotions.
• Supplier agreements: The project involved promoters, influencers, and partners, requiring aligned contractual protections.

Legal Strategy & Work Performed

1. Regulatory mapping: Conducted a multi-jurisdictional analysis of gambling laws, advertising restrictions, crypto-asset regulations, and consumer-protection law across key target markets.
2. Campaign re-positioning: Advised the client on implementing measures and actionable steps to avoid adverse regulatory and gambling qualifications.
3. Language & positioning: Drafted recommended messaging to avoid terms suggestive of betting, trading, speculations, profit expectation, or investment language, ensuring campaign materials align with advertising codes, championship rules and platform terms.
4. Platform policy compliance: Reviewed applicable e-sports league and social media policies, adapting the campaign’s design to fit within permitted promotional boundaries.
5. Supplier documentation: Drafted and reviewed agreements with promoters, influencers, and partners, including compliance warranties, liability allocation, and disclosure requirements.

Current Status

The campaign is progressing smoothly and is currently pending. Regulatory clearance has been secured in 2 out of 3 key jurisdictions, where the framework was confirmed to fall outside gambling and financial-promotion regimes. However, in one jurisdiction the authorities take a stricter stance, imposing numerous restrictions and complicating the rollout. We are working closely with the client to assess mitigation strategies, including structural adjustments, tailored campaign design, and alternative launch pathways, ensuring that the project remains compliant while preserving its core engagement features.

Key Takeaways

• Form matters more than substance: Careful language and token structuring can mean the difference between a fan engagement campaign and an unlicensed gambling scheme.
• Multi-layer compliance: Success required balancing gambling laws, crypto-asset regulations, advertising codes, and digital platform policies simultaneously.
• Contracts as safeguards: Agreements with influencers and partners must allocate liability and mandate compliance, protecting the project from external violations.
• Positioning is strategic: By framing tokens as entertainment-based fan engagement, the project avoided regulatory burdens while maintaining excitement for participants.