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I am just wondering how you would be able to detect that the user who asks to be whitelisted is genuine and not an already banned user coming back with a brand new IP (VPN, proxy, TOR), new email address, new username, and no connection with previously used BTC/ETH or other addresses. That could prove to be a tough background check.
I think this will require a KYC as i don't see any other way to monitor it. A ban user (IP based) can always go the public internet cafe and make a new account. Still wondering without KYC, is there any possibility ?