Compliance Roadmap

Rebellion is taking a phased approach to regulatory alignment:

Focus Area
Status

Entity Domicile

BVI or Cayman (token issuance) + separate operating LLC in U.S./EU in review

Legal Opinions

In process across U.S. DFS, UK, Brazil, and Germany

Money Service Licensing

Not required for current non-custodial model; FinCEN opinion pending

Asset Licensing

NASDAQ/NYSE licensing for equities in progress

Token/Game Classification

DFS-style opinions in 2 key U.S. states underway

We aim for a lean, modular structure that scales with regional clarity rather than a one-size-fits-all model.

KYC / AML / OFAC Screening

Though Rebellion is non-custodial, all wallet addresses receiving prize payouts will be screened using 3rd-party API tools (e.g., TRM Labs, Chainalysis).

  • Sanctions checks are run against OFAC, EU, and FATF lists

  • High-risk jurisdictions are auto-blocked or flagged for manual review

  • Anonymous wallets can play free modes but must pass light KYC for prize eligibility

Regional Restrictions & Free Mode

To comply with local laws:

  • Players in grey or restricted jurisdictions (e.g., certain U.S. states, China) can still play in Free Mode

  • These leagues offer simulated prizes (XP, badges, NFT rewards) or capped earnings (e.g., $25 max)

  • Full payouts require KYC and eligibility confirmation

This ensures Rebellion can grow while remaining flexible with evolving regulations.

Tax Reporting: Players receive annual statement; non-custodial model but we surface CSV exports / 1099 forms

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