For start, I've seen some things you may want to clear up:
1. You say you don't ask for identification, still, at account creation you're asking for First Name / Last Name.
Do they have to be the real name?!
2. From what I know, at least in Europe, Mastercard doesn't issue anonymous cards with amounts bigger than 250 EUR (iirc). Yours easily go bigger.
Are the cards indeed anonymous? And if so, how can you guarantee an user doesn't lose his money because Mastercard has closed his card?
Hi, let me answer your questions.
1. Correct, we don't ask for any personal information or identification. You can register your account and card to any name you want.
2. We are a registered company in Iceland, Iceland is not an EU member but in the economic Area (EEA) and the Schengen Area. So Directive 2019/1153 doesn't apply to us.