App that contains a feature that allows users to deposit money that they may use to purchase later or get refunded
<p>In my app / website, there is a feature for the user to deposit money that they could then use to purchase later or get refunded 3 months later.</p>
<p>What is the legal implication of this feature?</p>

<p>An incomplete list:</p>
<ul>
<li>Getting the money.<br />
How did you plan to get paid? Credit card? Paypal? Integrating those into a website in compliance with their terms of service is not easy. (I wouldn't touch credit card numbers, in particular, even with a ten-foot pole. Too much liability risk for weak implementations. Too many highly skilled attackers to pounce on any mistake.)</li>
<li>Distributing the App.<br />
Places like the Apple App Store have their own terms of service, especially regarding payment and in-app purchases. At a guess, Apple would reject your app, but if they allowed it, how does your withdrawal policy fit with the 30% cut they want from the initial transaction?</li>
<li>Holding the money.<br />
So there are user accounts with a <em>credit balance</em> that can be <em>withdrawn</em> again. Would you be able to repay them if all users withdraw at the same time? Where do you keep the money?</li>
<li>Currency risks.<br />
Say international customers pay in currency A, which the payment provider transforms into currency B. Then they want their money back, but exchange rates have changed. What do they get?</li>
<li>Knowing your customer.<br />
There would be money laundering concerns. Do you have the infrastructure to identify your customers? Can customers change the (re)payment method from one account to another? Can you handle withdrawals if a user no longer has the same credit card, for instance?</li>
<li>Scammers leaving you to hold the bag.<br />
Say a scammer tricks a victim into making a deposit, and then finds a way to redirect the withdrawal (see above). Would you be able to deal with the legal and administrative fallout?</li>
</ul>

internet