On second reading, I think what you're describing is that we use ecash tokens instead of CCs. Because ecash is better because it can be converted into money? That's exactly why it'd be money transmission. Fundamentally, ecash is subject to all the same laws that custodians are subject to -- because ecash mints are custodians.

The reason why Reward Sats are legal is because we are paying you our own money, and NOT money that someone had us send to you on their behalf.

Most of what you hear from ecash proponents about getting around laws is premised on lots of people breaking the law to run unregulated ecash mints. Their ecash future is premised on a mass protest - which is awesome, but it isn't magically legal, in fact, it's explicitly the opposite.