Inquiry on Google Play's Gambling Policy

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Sep 13, 2018, 5:01:48 AM via Website

Please reply if you have any ideas about this at all, especially if you're a lawyer or work for Google/Google Play. (sorry for the long read)
Quick note first: GP's policies seem to contradict themselves. (shown below)

Developers offering products within a game downloaded on Google Play or providing access to game content must use Google Play In-app Billing as the method of payment.
Developers offering products within another category of app downloaded on Google Play must use Google Play In-app Billing as the method of payment, except for the following cases:
Payment is solely for physical products
Payment is for digital content that may be consumed outside of the app itself (e.g. songs that can be played on other music players).

We allow content and services that facilitate online gambling, as long as they meet the following requirements:
...App must NOT be purchasable as a paid app on Google Play, nor use Google Play In-app Billing;

Beyond that contradictory bit, GP has a lot of parameter for gambling apps that I'm hitting a wall with.

What I'm making & how I want it to work: an app that allows users to make games in a unique programming language and publish/sell their games. My idea is that I use a currency ("coins") that users buy via in-app purchases and use those to buy 1. Copies of games* from other users who in turn get coins 2. items/upgrades/whatever from within the games* 3. Some premium features within the app
(this way i can just have a few in-app purchases for coins instead of hundreds or thousands of different IAP)
*published within my app compiled from my language that goes with it

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In addition, I want to make it possible for game devs to reward coins to players for beating high scores and/or getting certain achievements.
Most important to note is that coins will be exchangeable for real money (@ half the buying value [and yet devs will be making 2-4 times as much as with similar publishers])

All that considered, I realized users would be able to easily set up gambling and/or lottery games. At first, I was afraid of that, but then I realized money is nice and I wouldn't mind running a massive gambling ring.

Key problems
1. Minors can't gamble - (how do I filter out children from gambling-involved games?)
2. Google Play's policy states "App must be rated AO (Adult Only) or IARC equivalent" if gambling is involved - (That would likely bar me from cashing in on minors, even for games without a gambling edge)
3. Google play also requires that the "Developer must have a valid gambling license for each country in which the app is distributed." - (would I at all be able to get a license for gambling on such an app & if I can, would there be any reason I couldn't extend a license over all of the games/developers it publishes?)

First solution I've thought up: Don't allow minor users to play/get coins from games that both include in-game purchases and give coins out to players.
Second solution: Make two separate apps following the same idea: adult version made specifically for gambling games & the minor version banning/preventing such games
Third solution: (possibly mixed with the first one) only allowing games to give coins to players only from a cache of coins the developer has earned from ad views on that game or coins the developer bought themself (no coins would be allowed from game sales/in-app purchases thus the player paid nothing & it's not gambling)

Did anyone make it through all that text? Does anyone have ideas? Spot any legal grey-areas? Should I just drop the option for developers to give coins out?
Most importantly: Do you think I will be fine with United States (Illinois) laws & Google Play's Developer Policies if I go with solution #1?

Forgot one last thing... Google Play says gambling apps are 'Currently permitted in the UK, Ireland, and France only'. I don't know if this is because of US laws or GP, but does anyone have an idea on if that will change sometime or which of those three places is best to move to.

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