This promotion could be "cleaned up" by making it "Win your own personal deposit bonus".
The advert should stipulate the amount of deposit required, but then encourage the customer to do their best to win themselves as big a bonus as they can (subject to a CLEARLY DISPLAYED cap).
This would be enough to make the advert itself "honest".
Terms and Conditions would then lay down the procedures to follow, and the wagering requirements and exclusions relating to the offer.
There would still be an incentive to the customers, but they will not end up feeling cheated once they win a fat sum and end up having most of it "confiscated" when they try to redeem their "prize".
This could be backfiring, there may well be players who do well on this free play, but whose first impressions are tainted when they feel cheated out of what the advert promised. They may then decide not to become a regulat player at that casino after all, and would look at other casinos offering different types of opening offers, as their view of this particular offer type would by now be negative.
Empty Fruities Astern Capt'n
Back to port for unloading.
Full Sails - before we get raided ourselves.
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