Can one of the Gold Passport Concierges confirm?
I guess if the expiration date on the certificate is not in at least 10-point type on the front of the card, then it might be exempt.
This is an excerpt from the link posted above:
Certain gift certificates or gift cards sold after January 1, 1998, are not subject to any of the rules discussed here. To be exempt, these gift certificates or gift cards must contain an expiration date, if any, in capital letters in at least 10-point type on the front of the card and must be either:
Distributed by the issuer to a consumer without charge under an awards, loyalty or promotional program; or
Donated or sold below face value at a volume discount to employers or to nonprofit and charitable organizations for fundraising purposes, if the expiration date is 30 days or less after the date of sale; or
Issued for perishable food products.