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But I assume you've probably already talked with some very smart lawyers who have explained why it's not actually equivalent to a gift card.
This stuff is all so new, every lawyer you talk to will tell you something different at the margins. But, fundamentally:
  1. we CANNOT custody money while it's in transit from person A to person B (without mtl/fsb licenses)
  2. we CAN custody our own money that we are paying to person C