Regulatory Position – United Kingdom

1. Platform Overview

Elite64 operates as a digital skill-based competition platform. Players compete in chess tournaments for cash prizes. The platform is operated by Synergy Digital Services Ltd, a company registered in England & Wales (Co. No. 16998181), with its registered office at 71-75 Shelton Street, London, WC2H 9JQ, United Kingdom.

2. Payment Processing

In Phase 1, all payment processing is exclusively handled by Stripe, an Electronic Money Institution authorised and regulated by the UK Financial Conduct Authority (FCA).

Elite64 does not hold client funds, operate payment accounts, issue electronic money, or provide regulated payment services.

All buy-ins are processed via Stripe PaymentIntents with manual capture. Funds are held within Stripe's regulated infrastructure until the tournament starts, at which point they are captured. If a tournament is cancelled, the authorisation is released with zero fees to the player.

3. Fund Custody & Payouts

Funds are held within Stripe's regulated account at all times. Elite64 does not operate any internal wallet, stored value system, or segregated client bank account.

Prize payouts are executed exclusively through Stripe Connect Express. Each winning player receives their prize via a verified Stripe connected account. Elite64 does not initiate any direct bank transfers outside of Stripe's infrastructure.

Players cannot deposit funds independently. Payments are only accepted as tournament entry fees, directly linked to a specific tournament. There is no stored balance, no pre-funding, and no internal credit system.

4. Regulatory Position

Based on the current architecture and applicable UK regulations, Elite64 does not require authorisation or registration as a Payment Institution or Electronic Money Institution in the United Kingdom.

Specifically:

• Elite64 does not hold client funds — all funds are held by Stripe (authorised EMI).
• Elite64 does not execute payment transactions — Stripe processes all payments.
• Elite64 does not issue electronic money — there is no wallet, no stored value, no prepaid balance.
• Elite64 does not operate payment accounts — there are no customer accounts with depositable/withdrawable balances.

Stripe, as the authorised EMI, carries the regulatory obligations for safeguarding client funds and processing payments in compliance with UK FCA requirements.