How about recycling Oasis (which I remember to be a “Open Asset Swap Interaction Scheme”, so not necessarily fiat money related), as a tool to convert cryptocurrencies only, among themselves ?
No banking license would be needed.
No questions to be addressed, no people to be convinced.
All you need is to find a crypto liquidity provider (it should not be that difficult).
Which coins could actually bring real organic demand for this tool ?
Monero (XMR) and Bitcoin (BTC).
If you make this tool, it would definitely create BIG waves within the crypto sphere, as people could be able to swap XMR/BTC in a permissionless way, secured by HTLC.
I get that the guys at MICA could always find something to object, but the tool would be permissionless and not strictly hosted in Europe or advertised to europeans.