The angle I’m exploring isn’t to bypass regulation, but whether a non-custodial, self-hosted orchestration layer can exist that never holds funds and only works on rails that already support direct settlement. The model is closer to paying a shop directly than paying through an intermediary....the software is never a counterparty, never pools funds, and the regulated entities remain the banks or processors on both ends.
In a US scenario, the idea would be that the merchant runs the software themselves, and onboarding doesn’t abstract compliance away but explicitly guides them through what they need in place to legally accept payments, linking out to the appropriate providers and only working once those are set up. My question is whether, in your view, that meaningfully changes the regulatory posture, or if simply being part of the payment initiation path still makes MSB treatment unavoidable.
Appreciate you calling this out....it’s exactly the constraint I’m trying to understand.