Anti-Money Laundering, Sanctions, and Prohibited Use Policy

1. Purpose and scope

Outlier Collective, Inc. d/b/a LVL6 (“LVL6,” “we,” “us,” or “our”) is committed to preventing the Service from being used for money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful or abusive activity.

This Anti-Money Laundering, Sanctions, and Prohibited Use Policy (“Policy”) applies to lvl6.com, LVL6 accounts, portfolio and market tools, Play, customer support, promotions, and any paid pack, Vault, buyback, payout, or shipping feature that LVL6 enables (collectively, the “Service”). This Policy is part of and subject to the Terms of Service. Defined terms have the meanings given in the Terms unless this Policy says otherwise.

Our controls are intended to protect users, LVL6, our providers, and the integrity of the Service; meet applicable legal and contractual requirements; and identify activity that warrants review. This public Policy does not describe every internal control or establish that LVL6 is a bank, financial institution, or money services business.

2. Current and future features

Play currently uses promotional Play credits granted by LVL6. Those credits are not sold, have no cash value, and are not deposits or stored value. Provisions in this Policy concerning user payments, paid packs, buybacks, cash out, or other paid activity apply only when LVL6 expressly enables the relevant feature.

An opening may assign an identified physical collectible to a user as described in the Terms. An assigned item does not make promotional credits withdrawable and does not by itself create a right to a cash payout. Shipping, sale, and buyback options apply only when displayed as available for the item and remain subject to this Policy.

LVL6 does not offer the Service as a bank account, deposit account, general-purpose wallet, exchange, escrow service, or money-transfer service. Users may not attempt to use purchases, credits, collectibles, buybacks, refunds, or payouts to replicate one of those services or to move value for another person.

3. Prohibited use

You may not use, attempt to use, or help another person use the Service to:

• launder money, finance terrorism, conceal proceeds of crime, or disguise the source, ownership, location, movement, or control of funds or property;
• violate, evade, or circumvent sanctions, export controls, trade restrictions, geographic limits, court orders, or other legal restrictions;
• use proceeds of unlawful activity, stolen property, a compromised account, or a payment or payout method you do not own or have authority to use;
• transact for an undisclosed third party, nominee, intermediary, or beneficial owner, or allow another person to control your account;
• split, layer, cycle, or structure activity to avoid a limit, verification request, review, hold, reporting rule, or other control;
• conduct sham, wash, circular, collusive, or artificially repetitive purchases, assignments, sales, buybacks, refunds, or payouts;
• exploit pricing, odds, inventory, promotions, rewards, referrals, Account Credits, shipping, chargebacks, refunds, or technical errors;
• create or coordinate multiple accounts to evade eligibility rules, limits, reviews, suspensions, or enforcement actions;
• use false, incomplete, stolen, altered, or misleading identity, contact, payment, payout, tax, or shipping information;
• use a proxy, virtual private network, remote-access tool, location spoofing, or similar method to misrepresent your identity or location or evade a control;
• interfere with or test the limits of fraud, sanctions, security, identity, transaction-monitoring, or eligibility systems; or
• engage in fraud, scams, trafficking, ransomware, theft, corruption, counterfeiting, market manipulation, or any other illegal or prohibited conduct.

These examples are not exhaustive. Conduct may be prohibited when it violates the Terms, applicable law, a provider requirement, or the intended collectible purpose of the Service.

4. Sanctions and eligibility

The Service is offered only to eligible users who are at least 18 and physically located in the United States. You may not use the Service if doing so would cause you, LVL6, or a provider to violate an applicable sanctions program, export control, trade restriction, or other law.

You may not use the Service if you are, or are acting for or benefiting:

• a person or entity identified on an applicable blocked-person, sanctions, restricted-party, or denied-party list;
• an entity blocked because of ownership or control by a sanctioned person;
• a government, jurisdiction, organization, or person with whom the applicable transaction is prohibited; or
• any other party that applicable law or a provider prevents LVL6 from serving.

U.S. sanctions can be geographic or targeted and change over time. The U.S. Department of the Treasury's Office of Foreign Assets Control publishes current sanctions-program information. We may change eligibility or restrict a location, payment method, payout destination, shipment, or counterparty when necessary to follow law, provider requirements, or our risk controls.

5. User duties and verification

You must use the Service only for yourself, maintain one authorized account, provide accurate and complete information, keep that information current, and use only payment and payout methods that you own or are authorized to use. You must promptly respond to reasonable verification and information requests.

Basic account creation may not require government identification. Based on the feature, transaction, risk, or legal requirement, LVL6 or its providers may request a legal name, date of birth, address, telephone number, tax information, payment or payout details, source of funds or property, proof of account control, government-issued identification, selfie or liveness check, shipping evidence, or other information reasonably needed for a review.

We may verify information before or after account creation and before or after a purchase, item assignment, shipment, buyback, refund, or payout. If you do not provide requested information, or if we cannot reasonably verify it, we may decline, delay, or restrict the affected activity.

Where a user, beneficial owner, or other relevant party is identified as a politically exposed person (“PEP”), or as a close associate or family member of a PEP, LVL6 applies risk-based enhanced due diligence. Depending on the circumstances, this may include additional identity and ownership verification, source-of-funds or source-of-wealth information, the purpose and expected nature of the relationship, approval by the AML Compliance Officer, and enhanced ongoing monitoring. PEP status alone does not automatically prohibit use of the Service; decisions are based on the facts, applicable law, provider requirements, and the risk presented.

6. Risk and activity reviews

LVL6 and its providers may use risk-based reviews, automated signals, manual review, sanctions screening, identity verification, payment controls, fraud-prevention tools, and activity monitoring. Relevant information may include account and device data, IP-derived region, contact and identity information, payment and payout metadata, purchase and opening activity, Vault history, buybacks, refunds, chargebacks, shipment details, linked accounts, and communications.

Activity may receive additional review when it involves, for example:

• unusual value, volume, frequency, velocity, or timing;
• rapid purchase, buyback, refund, or payout activity without a reasonable collectible purpose;
• related accounts, devices, payment methods, payout destinations, or addresses used in a way that appears coordinated or evasive;
• identity, location, payment, payout, shipping, or account information that is inconsistent or cannot be verified;
• attempts to evade limits, reverse payments after receiving value, or exploit promotions or technical errors; or
• information from a payment provider, identity provider, carrier, law-enforcement agency, regulator, sanctions authority, or other reliable source indicating elevated risk.

Review criteria are not limited to this list, and LVL6 does not disclose confidential thresholds or detection methods.

7. Transaction controls

When paid features are enabled, purchase funds may be used only for eligible goods or features. Purchase funds, promotional credits, refunds, rewards, points, and bonuses are not deposits and may not be transferred, exchanged, or withdrawn except where the Terms or applicable law expressly provide otherwise.

Only amounts LVL6 owes after completing a bona fide purchase of an eligible physical collectible are Eligible Sale Proceeds. Buying or opening a pack, adding purchase funds, receiving a refund, or receiving promotional value does not by itself create cash-out rights. A buyback or payout may be subject to identity, ownership, tax, sanctions, fraud, payment-finality, destination, and other reviews.

You may not use LVL6 as a pass-through account, stored-value product, exchange, off-ramp, or money-transfer service. Third-party funding, direct or indirect conversion of purchase funds into payouts, and activity designed primarily to move or disguise value are prohibited.

8. Vault and shipping

LVL6 may review an item assignment, Vault transfer, storage decision, sale, buyback, or shipping request for ownership, payment, fraud, sanctions, location, insurance, carrier, tax, and other compliance concerns.

We may require additional verification or delay, deny, cancel, or restrict a shipment when an address is incomplete, unverifiable, prohibited, or inconsistent with account information; when an account or item is under review; when requested information is not provided; or when shipment would violate law, carrier rules, provider requirements, the Terms, or this Policy.

9. Holds and enforcement

To the extent permitted by law and the Terms, LVL6 may take one or more actions when activity presents fraud, sanctions, financial-crime, security, legal, provider, or other material risk. Actions may include:

• requesting information or enhanced verification;
• reviewing, delaying, limiting, rejecting, canceling, or reversing an activity when reversal is legally and operationally available;
• declining to credit an account or withholding a shipment, refund, buyback, reward, promotion, or payout pending review;
• canceling or recovering credits, rewards, referral benefits, or proceeds obtained through fraud, error, abuse, or prohibited use;
• suspending, restricting, or terminating an account;
• blocking or rejecting property or a transaction when required by sanctions or other law; and
• sharing information or reporting activity as described below.

If an account is terminated while the user owns an eligible Vault item, LVL6 will provide a legally compliant process to ship the item or complete an available sale, subject to identity and ownership verification, payment finality, sanctions restrictions, legal holds, taxes, fees, and applicable law. We may be unable to deliver property or proceeds to a prohibited person or destination.

10. Program governance, training, and testing

AML Compliance Officer

Alexander Lin is designated as LVL6's AML Compliance Officer and AML program owner. The AML Compliance Officer is responsible for implementing and monitoring this Policy and related controls; maintaining a risk assessment; overseeing screening, enhanced due diligence, investigations, escalation, recordkeeping, training, testing, and corrective action; coordinating with relevant providers; and reporting material issues and the program's status to senior management. The AML Compliance Officer will receive authority, access to information, and resources appropriate to LVL6's products, size, and risk profile.

Personnel training

Personnel and contractors whose responsibilities involve user onboarding, payments, payouts, fraud, sanctions, compliance, customer support, Vault operations, fulfillment, or other relevant controls receive role-appropriate AML and sanctions training when they assume those responsibilities and at least annually thereafter. Additional training is provided when material legal, product, risk, or control changes warrant it. LVL6 documents training content, dates, and attendance and follows up on incomplete training.

Independent program testing

LVL6 conducts risk-based testing of its AML and sanctions compliance program at least annually and after material changes when the risk warrants additional review. Testing is performed by qualified personnel who are independent of the day-to-day operation of the controls being tested or by a qualified external party. Testing may evaluate the risk assessment, screening, due diligence, monitoring, escalation, enforcement, reporting, recordkeeping, training, and provider oversight. Material findings are documented and reported to senior management, and the AML Compliance Officer tracks corrective actions through resolution.

11. Records and privacy

We may maintain records concerning accounts, identity and eligibility reviews, payments, purchase funds, credits, pack openings, assigned items, Vault activity, buybacks, payouts, refunds, chargebacks, rewards, shipments, disputes, sanctions screening, fraud reviews, compliance decisions, and enforcement actions.

Records supporting this AML and sanctions compliance program, including relevant verification, screening, due-diligence, transaction, case-review, escalation, reporting, training, testing, and corrective-action records, are retained for at least five years after the later of the record's creation, completion of the related activity, or account closure, as applicable. We retain records longer when required by law, legal process, a preservation obligation, a provider requirement, or a documented business need. Records are maintained in a form that can be retrieved within a reasonable time and are protected against unauthorized access or alteration. Our Privacy Policy provides more information about data handling, disclosure, retention, and user rights.

12. Reporting and cooperation

LVL6 may share relevant information with payment, identity, fraud-prevention, sanctions-screening, payout, fulfillment, shipping, insurance, banking, accounting, legal, and other providers when reasonably necessary to review or protect an activity.

We may report suspected fraud, sanctions violations, prohibited use, or unlawful activity to a provider, financial institution, carrier, insurer, regulator, sanctions authority, law-enforcement agency, or other appropriate recipient when permitted or required by law. We may preserve records and cooperate with subpoenas, court orders, legal process, regulatory requests, provider investigations, and lawful government inquiries.

LVL6 may be unable to tell you whether a report was made or describe a review, hold, or information request when notice is prohibited by law, could compromise security or an investigation, or would reveal confidential controls.

13. Policy changes

We may update this Policy as the Service, applicable law, sanctions, provider requirements, or our risk controls change. The “Last updated” date identifies the current version. When a change is material, we may provide additional notice through the Service, by email, or by another reasonable method. Continued use after an update takes effect constitutes acceptance to the extent permitted by law.

14. Contact

Questions or good-faith concerns about this Policy may be sent to help@lvl6.com with the subject “LVL6 AML Compliance” or mailed to:

LVL6
1027 Alma Street
STE B
Palo Alto, CA 94301
United States

Do not include passwords, one-time codes, full payment-card numbers, or other unnecessary sensitive information in a report.