I had the same concern that you mentioned, so I decided to play it safe and ask them up front if it’s okay to give my players “external” bonuses. They said it was okay, which I was a little surprised about.
Better get this in writing as you could find that you will forfeit a large commission check and to add insult to injury be out the incentive monies too!
Most casinos will NOT allow you to incentivize players under a CPA model. If they allow it at all its strictly under a Net Win or Percentage of deposit scheme ONLY.
Carefully read the published Terms and Conditions and require a written exclussion for providing a cash incentive to players on a CPA commission plan. A verbal agreement will not be honored and should not be the basis of moving forward with this plan.