Anti-Money-Laundering & Know Your Customer

This statement describes Cardhouse Ventures LLC's financial-crime posture: why the Service is structurally a poor vehicle for moving illicit value, what controls operate today, what does not yet exist, and what will trigger a review of an account. It is published because a customer is entitled to know how their money is handled, and because a control described in public is harder to quietly abandon.

1. Regulatory posture, stated plainly

Cardhouse Ventures LLC sells goods. It is not a bank, a credit union, a money services business, a money transmitter, a payment processor, an issuer of stored value redeemable for cash, a virtual-currency exchange, or a dealer in precious metals or securities.

Tokens are a closed-loop prepaid mechanism: they are sold by us, redeemable only with us, only for our own goods and services, and are not redeemable for cash. We take the view that this places them outside the licensing requirement of the California Money Transmission Act (Cal. Fin. Code § 2000 et seq.), which reaches the sale of stored value redeemable at persons other than the issuer, and outside the definition of a money services business at 31 C.F.R. § 1010.100(ff), which excludes closed-loop value that cannot be exchanged for money or monetary value.

That position is stated as our reasoned view of the law as applied to the architecture described below. It is not legal advice to you, it does not bind any regulator, and it is reviewed whenever the architecture changes. If the closed loop is ever opened — if value can be withdrawn, transferred between customers, or redeemed anywhere but here — this page and our licensing position change first, before the feature ships.

2. The architecture does most of the work

There is no outbound rail. Tokens are purchased with dollars and spent on packs, memberships and services. They cannot be withdrawn, cashed out, refunded to a card as tokens, converted to cryptocurrency, or sent to a bank account. Selling a card back to us pays tokens, never cash.

Value cannot move between accounts. There is no account-to-account token transfer, no gifting, no peer-to-peer sale and no open trading of cards between customers. Where any such feature is contemplated in future, it will be assessed against this page before it is built, not after.

There is a single inbound rail. Deposits are accepted only by payment card through Stripe, from an instrument in the account holder's own possession and name. We do not accept cash, cheques, wire transfers, money orders, cryptocurrency, prepaid instruments issued by third parties, or funding by anyone other than the account holder.

Goods, not instruments. What a customer receives is a trading card: a physical collectible of variable and publicly quoted value, not a bearer instrument. Cards ship only to the verified account holder's own address.

A closed loop with one inbound rail, no outbound rail, no inter-account transfer and a physical-goods output is among the least attractive laundering vehicles a consumer business can present. That is a deliberate design decision and it is the primary control; the procedural controls below sit on top of it.

3. Controls in operation today

Payment screening. Every deposit is authorised and screened by Stripe, including its fraud scoring, card-testing defences and sanctions screening, before a single token is credited. Tokens are credited only on a confirmed payment event received from Stripe over a signed webhook — never on a client-side success message.

Strong customer authentication. 3-D Secure is required on card payments, which places liability for fraudulent authenticated transactions with the issuer and materially reduces the value of the Service to a person using a stolen card.

Identity of access. Sign-in is operated by Clerk, with e-mail verification, optional two-factor authentication, and detection of credential-stuffing patterns.

Age attestation. Age is attested at sign-up and again before a first deposit. See the Terms for what a false attestation costs the person making it.

An append-only ledger. Every movement of tokens is written as an immutable ledger entry carrying its amount, reason and the object that caused it. The displayed balance is a cache and is reconciled against the sum of the ledger; any divergence is treated as a defect to be investigated, never rounded away. This is what makes an account's financial history reconstructable end to end, which is the practical substance behind most recordkeeping obligations.

Ownership provenance. Every card carries an ownership history from the moment it is drawn — which pack, which opening, which proof, which shipment — so a card's route through the Service can be traced without inference.

4. Controls not yet in place, named rather than implied

Below $2,500 in a single deposit we do not perform documentary identity verification. No government identification is collected and no identity-document check is run on those deposits. For a closed-loop retail product at those transaction sizes we consider that proportionate; we do not consider that it will remain proportionate.

Above $2,500 in a single deposit we do. A deposit over that amount cannot be started until the account has completed a documentary identity check — a government-issued document and a matching selfie — carried out by Stripe Identity. We receive the outcome only. We do not receive, store or have access to the document image, and we do not record a government identification number.

A formal customer risk rating, together with documentary verification at lower thresholds, will be introduced before any of the following: a further increase in deposit limits; shipping at material volume; the introduction of any transfer, trading or resale feature between customers; or any change permitting value to leave an account other than as goods.

We do not operate a formal AML compliance programme of the kind required of a financial institution — there is no designated compliance officer, no independent testing function and no automated suspicious-activity monitoring suite — because the Service is not a financial institution. Should the business change such that those obligations attach, they will be implemented before the change goes live, not after a regulator asks.

We would rather list these gaps than let a page of confident language imply a programme that does not exist.

5. What triggers a review

A chargeback, payment reversal or bank dispute; repeated failed or declined payments; a mismatch between the account holder and the cardholder; multiple accounts sharing a payment instrument, device or address; deposit immediately followed by an unusual shipping instruction; requests to redirect shipment to a third party; any attempt to fund from a source we do not accept; or any request that value be paid out in a form other than goods.

A review may result in a request for information, a temporary suspension of spending or shipping, or closure of the account. Suspension pauses activity; it does not confiscate a customer's cards. Where a dispute resolves in the customer's favour, the position restored is exactly the position taken.

A successful payment reversal automatically reverses the tokens that payment bought. Where those tokens have already been spent, the resulting negative balance is a debt to us and the account is suspended until it is settled.

6. Sanctions

We do not knowingly transact with any person or in any jurisdiction subject to sanctions administered by the U.S. Office of Foreign Assets Control, and we rely on Stripe's screening at the payment layer. Accounts identified as sanctioned are frozen, and no goods are shipped to a sanctioned destination.

7. Records and reporting

Financial records — the token ledger, the payment record, the ownership history of every card, and the proof of every pack opening — are retained for the period required by applicable tax, accounting and consumer-protection law, generally not less than seven years. Closing an account does not delete records we are required to keep.

Where we identify activity we reasonably believe to be unlawful, we will act on it, including by suspending accounts, refusing shipment, and reporting to law enforcement or the appropriate regulator. Where law or a lawful instruction prohibits us from disclosing that a report has been made, we will not disclose it, and our silence on the subject should not be read either way.

We respond to valid subpoenas, warrants and court orders. We do not volunteer customer records absent legal process or a genuine and articulable suspicion of unlawful activity.

8. Contact

Questions about this statement, or to report suspected misuse of the Service: support@cardhouse.live.

Questions about anything on this page: support@cardhouse.live