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Legal

AML and KYC Policy

Real-money play happens only with verified identity, screened counterparties, and monitored flows. None of that is required to play the free beta.

Purpose

This policy describes the anti-money-laundering (AML) and know-your-customer (KYC) program Rakefall (operated by ZipLyne LLC) will run wherever real-money play launches. The program will be finalized with counsel and tailored to each region's regulations as part of licensing, and no real-money play will be offered before it is in force for that region.

Status today

The Service is a free-play beta. There are no deposits, no withdrawals, no purchases, and no prizes with monetary value, so no identity verification is required to play. Connecting a wallet in the beta is optional and does not move value.

Verification before real-money play

Before an account can deposit, stake, or withdraw real value in a licensed region, we will require:

  • full legal name, date of birth, and residential address;
  • a government-issued identity document, checked for authenticity;
  • age verification against the region's minimum (18 or 21 plus);
  • screening against applicable sanctions and watchlists, including OFAC lists, and politically-exposed-person checks; and
  • enhanced due diligence, including source-of-funds evidence, where activity or risk indicators warrant it.

Ongoing monitoring

  • Transaction monitoring for patterns consistent with money laundering or fraud.
  • On-chain analytics on connected wallets, including screening against addresses linked to sanctioned or illicit activity.
  • Re-screening of verified players against updated sanctions lists.
  • Limits, holds, or account review where monitoring raises flags.

What we prohibit

  • Access to real-money play by anyone under the region's minimum age.
  • Access by sanctioned persons or from sanctioned or unlicensed jurisdictions.
  • Third-party funding: you may only play with value you control.
  • Multiple accounts, and any structuring of transfers to evade limits.

Reporting and cooperation

Where regulations require it, we will file suspicious-activity reports and cooperate with regulators and law enforcement. We may suspend accounts, hold funds, and refuse transactions while a review is open, to the extent the law allows or requires.

Records

Verification records and transaction logs for real-money play will be retained for the period each region's regulations require. Identity data is handled under our Privacy Policy.

Contact

Questions about this policy: legal@rakefall.com.