The problem is that Apple still wants to call it a transaction, I'm sure Apple would bitch if Feed The Children or some other donation app didn't use Apple for donations.

I wonder if there's some to be said about the fact it's not "money", like how would Apple want you to deal with that...

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Are you referring to the T’s and C’s?

“transaction” is only mentioned 4 times and only 1 of those is regarding a financial transaction to say exchanges are allowed to make crypto transactions.

https://developer.apple.com/app-store/review/guidelines/

Reading seems like if he worked with an "approved exchange" he could do it, looks like he already talked with them and they said the profile zaps were fine but not the note zaps....