How easy is it to integrate Zaps with a federated model? Is the server hosting the zaps now acting as a money transmitter? Do they have an obligation to obey OFAC?

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All above my pay grade, but I know there’s no reason the protocol couldn’t support it.

Also, Bluesky’s federation ≠ mastodon’s federation.

Very easy, most already have the rails. It's an Apple policy issue, mainly. X could turn on zaps but instead they limit tips to tipping profiles for policy reasons. Nostr isn't nearly as reliant on Apple.