While you are correct, casino chips are used for all those purposes, they are only supposed to be used at the casino for gambling. That is the intent. The fact that the original intent has been overstepped does not legitimize the activities. Nobody is suggesting (or at least I'm not suggesting) that anybody is going to crack down on a church for receiving chips as donations. Recent cases at the MGM have brought up the issue of cashing these chips if not involved in play (gambling play, not evening entertainment play). They aren't supposed to be used for the purposes of trade, they serve as markers, having no value onto themselves.

It is by no means an absolute that casino chips are used "in commerce". I wish whomever borrowed my Black's Law Dictionary would have returned it. It would be interesting to see what the legal definition of commerce is (legal definitions are not always the same as common definitions).