Taking 321 Lotto to Market — Even When Meta Said “No”

11.9M

impressions

32,705

messaging conversions created

21,331

new leads acquired

321 Group

Key Objectives

Launch 321 Lotto in PNG and build brand dominance from day one

Unblock 321 Group’s Meta infrastructure and get ads live

Develop a compliant, scalable paid social strategy for a regulated industry

Seek gambling ad approval from Meta to support long-term digital growth

Train the in-house team and document a handover strategy for ongoing success

Meta Ads Management

Social Media Marketing Meta Ads Management

INDUSTRY

Lottery

DURATION

4 months

PRESENCE

PNG

What We Did

Ad Account Restrictions Lifted

Successfully lifted restrictions on the Meta Business Manager and ad accounts, allowing campaigns to go live.

Acquisition Strategy Development

Developed an indirect acquisition strategy using awareness, engagement, and messaging campaigns to drive physical lottery sales without breaching Meta's gambling rules.

Campaign Launch

Launch 321 in Papua New Guinea, running national brand awareness and messaging campaigns across September to December 2024, leading to overwhelming demand and operational strain at launch.

Consultancy

Delivered extensive internal documentation, process training, and policy guidance to 321’s team for ongoing campaign execution.

Meta Escalation for PNG Gambling Ads

Worked directly with Meta’s Escalations Desk to argue for gambling ad approval in PNG — submitting a formal case backed by best-practice examples, legal support, and regulatory context.

Despite submitting a detailed, policy-compliant case supported by legal context and best-practice advertising frameworks, the application was ultimately denied, not due to content, execution, or compliance, but because Meta enforces a global policy that restricts gambling ads in Papua New Guinea. This position was confirmed through Meta’s Escalations Desk and reflects a platform-wide decision beyond advertiser or agency influence. A parallel request submitted via our contacts within TikTok’s Financial Services team received the same outcome, with both platforms citing globally enforced restrictions specific to the PNG region.

The Results

11.9Mimpressions with $0.07 CPC and 0.26 cost per conversation

32,705messaging conversations generated

21,331new leads acquired

With BFJ Digital's help, 321 Lotto launched successfully in PNG with nationwide awareness and high-volume engagement, despite advertising restrictions. Meta's policies could not be changed, but we created a workaround that delivered real growth, leads, and store activity, with one retail outlet selling 7,000 scratch cards daily, and 3.5 million more were ordered by distributors during the campaign. The campaign’s success has enabled 321 Group to continue expansion across other emerging markets with a proven go-to-market model.

BFJ Digital delivered not just execution, but a repeatable framework for regulated product marketing in complex environments.

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