AML & Identity Verification Policy
Last updated: 23 September 2026
CONCLAVE takes payments in and pays nothing out: we sell relics ourselves, players cannot list or sell items to other players, and tokens cannot be withdrawn or exchanged for money. This policy sets out the proportionate steps we take to keep the Service from being used to launder money or move the proceeds of crime — described as they actually work, at the scale this Service actually operates at. It should be read alongside our Payment Policy and Privacy Policy.
1. Pre-launch: nothing is being screened yet, because nothing is being charged
Paid top-ups are disabled during pre-launch. No card is charged, and so none of the controls below are being exercised on live money today. They describe the position from the moment top-ups are switched on. We would rather say that than publish a policy implying a programme is running when it is not.
2. What we actually do
Every top-up is processed by a licensed, regulated payment institution, which performs its own fraud and sanctions screening before any funds reach us. We rely on that institution to decline or flag transactions that trip its controls. We do not operate a separate automated screening system of our own, and this policy does not claim one.
We cooperate with that institution and, where the law requires it, with law enforcement investigating a specific transaction or account.
3. No payouts, no consignment
Money only moves one way on CONCLAVE: from a customer, through the payment institution, to us. We do not pay money out to players, there is no seller or consignment programme, and tokens have no cash value and cannot be withdrawn. Because nothing is paid out, there is no payout identity check to describe — and if that ever changes, this policy will be updated before any such feature goes live.
4. Ongoing monitoring
Automated monitoring of top-ups belongs to the payment institution and covers the patterns its own controls look for. On our side, a person reviews unusual activity — unusually large or frequent top-ups, or several accounts sharing payment details.
A flagged transaction may be held for review or refused. Where we are able to tell you why, we will; where the law prevents us from doing so, we cannot.
5. Sanctions
We do not knowingly provide the Service to any person subject to applicable UN, EU, UK or US (OFAC) sanctions. Sanctions screening of top-ups is carried out by the licensed payment institution that processes them, as part of its normal processing. On our side, CONCLAVE is not served to connections from Russia, Belarus, Iran, North Korea, Syria or Cuba (refused by IP address), and no account is opened for an email address registered in one of those countries. We do not screen names against sanctions lists ourselves.
6. Records we keep
Payment and order records are kept for as long as accounting and anti-money-laundering rules require, and are then deleted. Closing your account does not shorten that period — the Privacy Policy sets out every retention period in one place, and this one is stated there too so the two documents agree.
7. This does not limit your dispute rights
A hold, or a request for further information under this policy, is separate from — and never a restriction on — your right to raise a chargeback with your card issuer at any time. Our Payment Policy sets that out. If you see anything on CONCLAVE that looks like money laundering or fraud, tell us at support@conclave.academy.