No idea about the legal stuff. I have loosely related thoughts though.

For over a year custodial Alby seemed to route my lightning payments at no cost. I might have missed seeing the fees, but regardless they were almost 0. Shoutout to nostr:npub1getal6ykt05fsz5nqu4uld09nfj3y3qxmv8crys4aeut53unfvlqr80nfm. Coinos seems to be doing the same. Maybe with ecash they have more opportunities to make money.

Grateful for their service.