[otterley]

I'm totally speculating here, since I'm not intimately familiar with the pertinent regulations, but I think it's not going to be about the token's inherent properties as much as the mechanisms surrounding it.

With a token such as a laundry/car-wash token, an amusement ticket, or a Disney Dollar, you can't get cash back from the issuer. Once you buy them, they're yours forever, unless you can find a third party to give you money for them. The fact that you can (try to) sell them on eBay to a willing recipient doesn't make them currencies.

So I think it comes down to who controls the exchange. If it's a third party with no connections whatsoever to the issuer, then it's unlikely to be considered a currency. But if the issuer is also operating the exchange, or has a connection to the operator, then I think it's going to look a lot more suspect in the eyes of the law.

Again, this isn't legal advice - consult a licensed attorney in your jurisdiction.