There are laws around allowing withdrawals. If a service allows withdrawals, then they generally are considered a wallet and have to respect MSB laws.

But yea if you just have them as non-withdrawable credits then it might work. But at that point why not just do a simple top up?

The one advantage I'm aware of is the blinded custodian thing so thats +1 for ecash tokens.

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You can run a mint for yourself for only your application with exactly your requirements (limit withdrawals etc)! Hit me up if you need any information, happy to help.