Simulated Gambling Issue

Hello! I have an app - it is on sale with rating 12+. Since year 2018 I can't update it. Apple review says to me that according to  2.3.6 rating I selected is inconsistent quote:

Since your app includes features that simulate gambling, your ratings must reflect a "Frequent/Intense" setting for "Simulated Gambling"

My response is that this app is an utility for board game players, they need to simulate dice rolls. Also in the app there is no currency, entrance cost, goal or rules. It is dice simulator, but dices used not only for gambling.

And here is interesting things happen, they agreed and telling me to choose rating on the app with "simulated gambling" - none. I've done that and sent to review back. And still gets rejected because simulated gambling is set to none.
I have a feeling that I'm talking to a bot, because this situation repeated 2 times. And now... 2 years have passed... And I get same rejection reason 2.3.6 for newly uploaded build.

PS: You may ask, why don't you just set rating 17+ with simulated gambling - frequent and release it?

In order to reduce fraudulent activity on the App Store and comply with government requests to address illegal online gambling activity, we are no longer allowing gambling apps submitted by individual developers. This includes both real money gambling apps as well as apps that simulate a gambling experience.
We found that you have submitted this app under an individual account and indicated in the Ratings section of App Store Connect that it contains Simulated Gambling. While you can no longer distribute gambling apps from this account, you may continue to submit and distribute other types of apps to the App Store. 
Going forward only verified accounts from incorporated business entities may submit gambling apps for distribution on the App Store. Visit the Enrollment page to learn more about enrolling an organization in the Apple Developer Program. For information on transferring an app to another developer account, please review the App transfer overview page in App Store Connect Developer Help.

Does anybody had this issue? How can it possibly be solved?

I just want to update the app which is anyway on sale.
And I think the definition of "Simulated Gambling" is not accurate - If you don't have some sort of currency or recurring payments this is not a harmful "gambling" app.


just want to update the app which is anyway on sale. 

I think you've had as good a run as you could expect. The evolution of the guidelines is not in your favor, as they say, going forward. Time to let it go, I think.

Unfortunately it's apparently the rules of Apple Store.
I've got a rejected review for my poker lan/web poker on IOS due to the same reason.
It's simulating gambling even if you don't ask or charge them for a real game as they could do it either.
They precise in the message that you have to register as a company.

So if your app has been going well maybe you could do that.

Faced the same issue, and have been arguing with the review team for the whole day. 30 seconds ago, they approved my update. what I did is, in the "Note" section, explaining the features and functionalities of my app, and why it's not related to simulated gambling