Shoot, this is not good. Hopefully they can win their case, because they weren't custodial, but it sucks that they have to go through this anyway.
Discussion
Yeah, for selfish reasons the most worrying part is the implication that you can be a money transmitter without actually being custodial (which was more or less the current consensus)
Yeah, that is downright wild
The chance that they allow them to get away from this is basically zero.