Draft prepared for legal review. This policy is written to describe a program GameBreakers intends to operate; several pieces (identity-verification vendor, formal compliance officer designation, SAR filing procedure) are placeholders describing intended design, not a claim that they are already fully implemented. Do not publish or rely on this as evidence of actual regulatory compliance until reviewed by counsel and, where applicable, registered with FinCEN and relevant state regulators.
GameBreakers Anti-Money-Laundering & Know-Your-Customer Policy
Version: 2026-10-17 Effective Date: 2026-10-17
1. Purpose
Because GameBreakers holds user funds in a custodial wallet and moves funds between users based on Challenge outcomes, we maintain an anti-money-laundering (AML) and know-your-customer (KYC) program designed to detect and prevent the platform from being used to launder money, finance illegal activity, or evade sanctions.
2. Customer Identification Program (CIP)
At minimum, we collect a name, email address, state of residence and payment method for every account before it can deposit funds. GameBreakers serves U.S. residents only, and only in the states listed as Eligible States in our Terms of Service (Section 10). The residence an account declares is confirmed against the address on its government ID during identity verification, and the address on the ID takes precedence. Each entry fee and deposit is also checked against the user's physical location (IP geolocation with VPN/proxy detection) and, for deposits, the card's issuing country and the billing address. {{KYC_VENDOR_PLACEHOLDER}}: for accounts exceeding {{IDENTITY_VERIFICATION_THRESHOLD — e.g. $2,000 in cumulative deposits or any single withdrawal above $600}}, GameBreakers requires enhanced identity verification (government ID and, where applicable, proof of address) through a third-party identity verification provider before funds can be withdrawn. This enhanced verification step is a planned integration and must be connected to a real vendor before the platform processes real-money transactions at scale.
3. Transaction Monitoring & Limits
- Deposits are capped per-transaction and, optionally, per-day via user-configurable and platform-configurable limits (see our Responsible Play Policy).
- We monitor for patterns consistent with structuring (multiple deposits just under a reporting threshold), rapid deposit-and-withdraw cycles with minimal platform activity in between, and funding from or withdrawal to payment instruments not associated with the account holder.
- Accounts flagged by monitoring may have deposits/withdrawals paused pending manual review.
4. Suspicious Activity
Where required by applicable law, GameBreakers will report suspicious activity to the appropriate financial-crimes authority (e.g., filing a Suspicious Activity Report with FinCEN in the United States, where GameBreakers is required to register and do so). {{COMPLIANCE_OFFICER_PLACEHOLDER}}: a designated compliance contact responsible for this program must be named before public launch.
5. Sanctions Screening
Identity verification is required before any withdrawal. When an identity is verified, GameBreakers screens the account holder's full legal name, as shown on their government ID, against the U.S. Treasury Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List, and re-screens every verified account daily against the current list. A potential match is reviewed by staff using the date of birth and other identifiers before verification can be completed, and no payout is made while a match is unresolved. Accounts confirmed to match a sanctioned party will be frozen and funds blocked and reported in accordance with applicable law. Sign-up, entry fees, deposits and withdrawals are refused from countries and regions under comprehensive U.S. sanctions, and from connections that appear to use a VPN, proxy or Tor. Every location check, allowed or refused, is recorded with the time, the IP-derived location and the account's residence, and kept with the other records in Section 6.
6. Recordkeeping
We retain records of account identity information, deposits, withdrawals, and Challenge outcomes for at least {{RECORD_RETENTION_PERIOD — e.g. 5 years}}, consistent with standard AML recordkeeping expectations, subject to confirmation of the exact period with counsel.
7. Prohibited Uses
You may not use GameBreakers to launder money, structure transactions to evade reporting thresholds, fund the platform with a payment instrument that is not yours, or accept funding from a third party in exchange for controlling Challenge outcomes on their behalf.
8. Cooperation with Law Enforcement
GameBreakers cooperates with law enforcement and regulatory inquiries as required by applicable law and will disclose account information pursuant to valid legal process.