Yes, that is pretty much the case - the WSLCB says that retailers need to sell beer, wine & spirits for above the cost they pay for it, and that free alcohol cannot be used in promotions or advertising (I believe the most relevant legal code and the cases where it does not apply are in WAC 314-11-085). When people pay for a gift certificate for the same amount they can use that certificate to buy spirits as it is treated same as cash, however, when we donate gift certificates or give out ones that are good for things like 'Dinner for Two' then it is not the same as cash and spirits can not be purchased with them, if that makes any sense