Stripe Crypto Onramp for an Exchange

Stripe's crypto onramp handles KYC for the fiat-to-crypto purchase itself. Their website says the company acts as the merchant of record, handling regulatory requirements and compliance. It looks like people can create exchanges in the USA with implementing onramp, but where I think the hiccup would come from is holding a master wallet and generating wallets for customers to send and receive from, is consider custody. My understanding is that custodying customer funds generally makes you a money

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