[beerandt]

But this isn't Uber or even crypto.

There are clear definitions, regulations, and penalties for operating as a dollar holding/ transferring financial institution.

Especially since the percentage paid as a fee makes it essentially a defaulted account, or at least a service not provided and funds not returned.

These types of donation accounts have a long history at brick banks of helping those in need (while taking a hefty percentage off the top). It's not a new idea.

I suspect it's more likely this isn't lack of regulation, so much as a loophole or stretched legal definition. Maybe someone here is familiar with their regulatory classification. You don't launch something like this without reasonably ensuring the feds aren't coming after you.