2.71

Anti-Money Laundering and Anti-Fraud Policy

Last updated

2.71 does not want the Service used to launder money, commit fraud, or evade sanctions. This policy explains why that risk is low by design, what our payment processors and we do to keep it that way, and what happens if we suspect misuse.

We are a small digital-content business, not a bank, payment institution, or money transmitter. We do not hold funds for users and are not required to register as a financial institution. What follows describes the practical steps we and our payment processors take, not a regulatory certification.

1. Why the risk is structurally low

Coins are a closed-loop virtual currency, described in Terms of Service Section 4. They have no cash value and cannot be transferred between users, sold, exchanged, gifted, or withdrawn. The only thing you can do with a Coin is spend it on a generation inside the Service. There is no marketplace, no user-to-user payments, and no payout mechanism of any kind.

Because value only ever flows one way, from your payment method into Coins that are consumed inside the Service, there is no path for someone to deposit funds and later extract them as cash, goods, or a transfer to another person. That structure is the main reason the Service is a poor vehicle for money laundering: laundering requires getting value back out in a usable form, and the Service does not offer a way to do that.

We are not a money transmitter, do not custody user funds, and do not process payments ourselves.

2. Payment processors handle the regulated parts

Card and wallet payments are handled by Polar, acting as merchant of record for those transactions. Cryptocurrency payments are handled by NOWPayments. Both run their own know-your-customer (KYC), anti-money-laundering, sanctions, and fraud screening on the payments they process, under their own compliance programs.

We rely on that screening for the payment layer. We do not see or store full card numbers or wallet private keys, and we do not independently verify identity documents before a purchase.

3. What we do ourselves

On top of the processors' screening, we monitor account and purchase activity for patterns that suggest fraud or abuse, including:

  • unusually rapid or high-volume purchases (velocity);
  • many accounts funded from the same card, wallet, or payment method;
  • repeated failed or declined payment attempts;
  • a payment method's billing country that does not match the account's apparent location; and
  • purchases followed shortly by a chargeback or payment dispute.

When we see these patterns, or receive a report from a processor, a bank, or a user, we may refuse or reverse the transaction, ask you for additional information or proof of identity, place your account under review, and cooperate with our payment processors, banks, and law enforcement as appropriate. We keep transaction records for as long as required by law.

4. Sanctions

We do not knowingly provide the Service to individuals, entities, or territories subject to comprehensive sanctions administered by the U.S. Treasury's Office of Foreign Assets Control (OFAC). If we determine that an account or transaction involves a sanctioned party or region, we may block access, refuse or reverse the payment, and take any other step required by law.

5. Fraud we watch for

"Fraud" here covers unlawfully obtaining money, Coins, or access through deception, including:

  • payments made with stolen or unauthorized cards;
  • account takeover;
  • abuse of promotions, bonuses, or referral credit;
  • operating multiple accounts to exploit free or discounted offers; and
  • chargeback abuse, sometimes called "friendly fraud," where a user disputes a legitimate charge after receiving the Coins or content it paid for, and refund fraud more generally.

6. Consequences

Where we determine that a transaction or account is connected to money laundering, sanctions evasion, or fraud, we may take any of the following, alone or together: reverse the transaction, remove the Coins involved, suspend or permanently terminate the account with any remaining Coins forfeited as described in Terms of Service Section 13, refer the matter to law enforcement or a regulator, and seek recovery of any resulting costs where the law allows it.

7. Cryptocurrency payments

Crypto payments must be sent through NOWPayments in full, on the correct network, and within the 24-hour payment window. We credit Coins only for confirmed on-chain payments that meet those conditions. We do not knowingly accept payments from mixers, tumblers, or addresses that our processor flags as sanctioned or high-risk. Late, partial, or otherwise non-conforming crypto payments are handled under the Refund Policy, not credited automatically.

8. Your obligations

You must use only payment methods you are authorized to use, provide accurate billing information, and not use the Service, or attempt to use it, to move, store, or disguise the origin of funds. Do not share your account or Coins, and do not act on behalf of someone else without disclosing that to us if we ask.

9. Reporting suspected fraud or unauthorized use

If you believe your payment method was used on the Service without your authorization, or you suspect money laundering, sanctions evasion, or fraud involving the Service, email legal@271.dev with as much detail as you can provide (the account involved, the transaction, and why you believe it is suspicious). See the Complaint Policy for how we handle reports, and the Acceptable Use Policy for other conduct rules.

10. Policy review

We review this policy periodically and update it as our processors, product, or legal obligations change. Material changes will be reflected by an updated date at the top of this page.

11. Contact

Questions about this policy, or reports of suspected money laundering or fraud, can be sent to legal@271.dev.