Just to be clear i really don't understand the legal aspects, with that said.
If you don't give the option to off ramp it's just a purchase, right? Make a disclaimer of it and when trey discover the real beauty and opt to the real deal, they'll have a secured generated nsec, with a beautiful profile page, reasonable relay options and the connections made in the period.
Depends where you are, parting with it in any fashion here is considered subject to capital gains.
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Unless it is just between your exchange & one of your wallets that is.
Between your wallets whether self custody or your wallet (like wallet of Satoshi) on an exchange I mean.
