There are exclusions for low amounts in some regs. There’s just little to no way to hold small, dust amounts of bitcoin yourself. Not a lawyer but there would be a clear upgrade path and threshold, there really isn’t an alternative 🤷🏻♂️
Discussion
You could use ecash to do LSP fee credits. Before StashPay I thought about building a mint just for fee credits that LSPs could integrate. But I got stuck on the regulatory part. You’d have to prevent users from spending until they have enough sats to open a channel. And there is a loss of privacy, since you couldn’t keep track of amounts to stay within legal limits. Otherwise you’d just end up hosting a mint for folks and custody their funds without limits.