I think this is challenging. The Bitcoin.com faucet had to be shut down because of abuse. The cat-and-mouse security model you propose is expensive and not convincing to me.
Also, not being able to withdraw the startup money would put a stop into anyone making multiple accounts, besides from maybe spam, which would be pointless.
how would this be done? start up accounts have private keys under memo.cash control? or memo.cash wouldn't share the private key until some action is taken?