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Regulatory clarity on Pay More or Less

Legal considerations pertaining to gaming regulations, anti-money laundering compliance, and 1099-K tax forms.

1. Gaming Regulations.

 

Pay More or Less does not grant users monetary winnings. Instead, a user’s deposit is merely refunded if the user "wins", while no net profit is ever distributed. This structure departs fundamentally from gaming, where participants can receive net gains. Furthermore, the platform offers a no-purchase-necessary entry mechanism, a cryptographic puzzle, resembling sweepstakes methods already being used by PayPalRobinhood and Coinbase. Consequently, participants may enter without any financial commitment.

 

From a financial standpoint, merchants always receive the product’s standard price, irrespective of whether the deposit is refunded or retained, and therefore incur no revenue loss. Critically, merchants also bear no legal exposure because all determinations of “win” or “lose” occur exclusively on the Pay More or Less platform, insulating merchants from gaming-related oversight or liability.

 

2. Anti-Money Laundering (AML) Compliance.

 

Because no net payout is ever issued, Pay More or Less does not trigger extensive Know Your Customer (KYC) or AML. If the user “wins,” the deposit is returned, and if the user “loses,” the deposit is simply applied as the product’s cost, thus there is no payout fund flow with heightened AML requirements. 

 

Moreover, Pay More or Less restricts transactions to U.S.-regulated financial institutions (e.g., PayPal, Coinbase), explicitly prohibiting transactions from self-custody wallets. This measure ensures that all funds originate from entities subject to federal and state oversight, thereby further reducing AML risk.

 

3. 1099-K tax forms.

 

Because users do not receive any profit or net proceeds, Pay More or Less does not generate a reportable income event for participants. If the user “wins,” the deposit is merely refunded rather than being disbursed as winnings; if the user “loses,” the deposit converts into the product’s purchase price.

 

Under this structure, no 1099-K forms or equivalent tax documentation are required, and customers are relieved of any tax-filing burdens. By eliminating monetary payouts, Pay More or Less obviates the primary triggers for income-related tax reporting, ensuring a simpler compliance framework for both merchants and users alike.

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