No imo. The general spirit of most money transmitter laws is consumer protection, ie protection from false claims like "If you give me money, I'll give it to this specific person for you."

Not legal advice, but if it were a donation to the faucet and the faucet chose to "drip" it to people at its own discretion then the faucet is simply spending its own money.

k00b

Thanks for replying, so in your opinion would a lightning faucet count as a money transmitter? So user A adds a reward and some user claims it.

chris42

SN elects to go noncustodial on Nov. 5th - FAQ & AMA

The distinction is subtle but again, just my understanding, is that the poster/commenter/zapper doesn't not spend with the intent of giving the territory founder money. SN isn't taking custody of money as party A gives it to party B. SN is merely cutting the territory founder into SN's own revenue like it does with rewards - albeit more predictably.