It won't even take ICANN, since I seriously doubt they are accredited themselves. They are probably dealing with one or more resellers and may well be breaching the terms of their agreements with those resellers.
You don't think they have look this up before they started to build this service? I'm pretty sure they have been thinking of every little scenarios that might come up and double check with all parts involved.
It really wouldn't be the first time a startup hadn't fully checked the regulations that would affect them, or decided to take their chances with flaunting them…