Anti-Money Laundering, KYC and Sanctions Policy

Arcade Processing LLC d/b/a CardOutpost

Effective Date: April 1, 2026 · Last updated: May 13, 2026

1. About CardOutpost

CardOutpost is a digital trading card pack-opening platform operated by Arcade Processing LLC ("Arcade Processing LLC"). Users deposit funds, purchase virtual packs containing randomized digital trading cards based on weighted odds, and may sell cards back to the platform at 90% of displayed fair market value for site credit (Earnings Balance). Earnings Balance may be withdrawn via PayPal or Wise subject to identity verification and fraud review. The platform is not a casino, sportsbook, or gambling platform; users purchase a digital entertainment experience with the option to monetize received cards through the platform’s buyback feature.

Arcade Processing LLC adopts BSA-aligned controls voluntarily because we move user funds, support cash withdrawals, and operate under the compliance requirements of our payment service providers. The application of the Bank Secrecy Act and money services business registration requirements to digital collectible platforms is fact-specific; Arcade Processing LLC reviews its classification with counsel periodically and as facts change.

AML Compliance Officer (AMLCO): Luke Burmeister, Head of Experience and Legal Matters, appointed by Arcade Processing LLC on May 13, 2026. The AMLCO reports to the company’s management and has authority to suspend accounts, freeze balances, and escalate matters to law enforcement. Contact: support@cardoutpost.com.

2. Customer Identification (KYC)

Tier 1 — Deposit only.At signup we collect: full legal name, date of birth, residential address (U.S. or, where eligible, non-U.S.), mobile number, and email. All users undergo basic identity verification including government-issued photo ID and liveness check through Stripe Identity. Users who fail basic verification may be restricted from depositing. Our payment processor’s fraud tooling runs fraud screening (3DS, AVS, device and behavioral signals). Players can deposit and open packs but cannot withdraw.

Tier 2 — Withdrawal eligible.Before a player’s first withdrawal, Stripe Identity completes full verification: government-issued photo ID, live selfie with passive liveness, proof of address (utility bill or bank statement, last 90 days), and payment method ownership confirmation. Verification results are stored in the player’s compliance record.

Players must be 18+ (21+ in U.S. states where required, or older if required by their local age of majority) and verified to be located in an eligible jurisdiction (U.S. or, where eligible, non-U.S.) via our geolocation provider.

3. Sanctions and PEP Screening

Players are screened at onboarding and on an ongoing basis against the OFAC Specially Designated Nationals (SDN) List and consolidated sanctions lists, as well as politically exposed persons (PEP) and adverse media databases. Screening runs at two levels:

  • Our payment processor screens every payment instrument and account at the platform level.
  • Arcade Processing LLC screens player names and addresses on signup, on KYC completion, and continuously thereafter, including against PEP and adverse media lists.

A confirmed sanctions match results in immediate account suspension, freezing of all balances (Pack and Earnings), prompt escalation to the AMLCO, and reporting to OFAC and relevant payment processors (Stripe, PayPal, Wise) where required. PEP matches trigger enhanced due diligence and AMLCO review before the account is permitted to transact above standard thresholds.

4. Transaction Monitoring

We monitor deposits, pack purchases, card sales, and withdrawals continuously using signals from our payment processor’s fraud and risk tooling, and our internal rules engine. Monitoring is risk-based: high-risk users, instruments, and behaviors get more scrutiny.

Quantitative review thresholds. The following activity automatically triggers enhanced review by the AMLCO:

  • Aggregate deposits exceeding USD 2,000 within any rolling 24-hour window.
  • Aggregate deposits exceeding USD 10,000 within any rolling 30-day window.
  • Single withdrawal requests exceeding USD 500, or aggregate withdrawals exceeding USD 10,000 within any rolling 30-day window.
  • Any structuring pattern designed to stay below the thresholds above.

Behavioral red flags that trigger review:

  • Unusual deposit patterns, including the use of multiple payment methods in rapid succession.
  • Withdrawal requests that appear inconsistent with the user’s platform activity or engagement level.
  • Transaction sequences that suggest attempts to rapidly convert deposited funds to withdrawable credit without genuine platform participation.
  • Withdrawal velocity inconsistent with the player’s prior pattern.
  • Transactions structured to stay under verification or reporting thresholds.
  • ID document signals from Stripe Identity suggesting alteration or synthetic identity.
  • Unusual chargeback or dispute patterns, including friendly fraud.
  • Patterns previously associated with fraud rings or coordinated abuse.

Escalations go to the AMLCO on the same business day. The AMLCO decides whether to apply enhanced due diligence, request source of funds, restrict the account, or close it. All escalation decisions are logged.

5. Chargeback & Dispute Monitoring

All user deposits are monitored against Stripe dispute data in real time. Any user with an active dispute, chargeback, or bank inquiry on any deposit is immediately restricted from withdrawal and flagged for review. Users who file chargebacks without first contacting CardOutpost support are subject to immediate account termination, permanent ban from the platform, and forfeiture of all balances and cards. We do not allow chargeback users to remain on the platform under any circumstances.

6. Recordkeeping

We retain KYC files, sanctions and PEP screening results, transaction records, escalation logs, and training records for a minimum of five years from the date of the relevant transaction or account closure, whichever is later.

Where a user submits a deletion or erasure request under applicable privacy law (e.g., CCPA), we honor the request only to the extent it does not conflict with our regulatory recordkeeping obligations. AML, KYC, and sanctions records are retained for the full five-year period regardless of any deletion request, and the user is informed of this carve-out in writing.

7. Training

All employees with customer-facing, payments, fraud, or compliance responsibilities complete AML training within 30 days of joining and annually thereafter. Training covers our business, the regulatory framework, KYC procedures, sanctions and PEP screening, red flags, and this policy. Completion is logged.

8. Independent Testing

This policy and the underlying controls are tested at least annually by personnel functionally independent of compliance operations, or by an external firm. Findings are reported in writing to the AMLCO and management; remediation is tracked to closure.

9. Prohibited Users and Activity

CardOutpost is not available to:

  • Anyone under 18 (or under 21, in states where required).
  • Anyone on the OFAC SDN List or any other applicable sanctions list.
  • Anyone in a country or region under comprehensive U.S. sanctions.
  • Anyone previously offboarded by Arcade Processing LLC for fraud, abuse, chargebacks, or breach of these terms.
  • Anyone acting on behalf of an undisclosed third party.
  • Anyone using payment instruments not registered in their own name.
  • Anyone attempting to circumvent geographic, KYC, or withdrawal restrictions via VPNs, proxies, or location spoofing.

The platform may not be used to launder funds, evade sanctions or taxes, finance illegal activity, or in furtherance of any unlawful purpose. Players who attempt to use VPNs, proxies, or location-spoofing tools to circumvent geographic restrictions are subject to immediate suspension under Section 8 of the Terms of Service.

10. Policy Review

This policy is reviewed and approved annually, and after any material change to applicable law, our business model, or our processors’ requirements. The AMLCO is responsible for review and the company’s management approves the final version.