A bit OT:

There's a project trying to build a protocol to trade tokens. Essentially allowing anyone to build their own exchange: https://0xproject.com/

There's also a JS library to interact with the protocol: https://github.com/0xProject/0x.js

Yeah I think this is being built with it:

https://medium.com/@the0cean/announcing-the-0cean-85ae78e9bc...

A distributed, peer-to-peer network of independent exchanges is essentially what the Ripple project all about. They just call them 'gateways'.

https://ripple.com/

It appears to me that the trouble with building an exchange isn't the software, but the securities regulations involved in running one.

Woe to they who attempt to do so without counsel.

Absolutely, speaking as someone who built an exchange and spent a lot of time trying to figure out a legal route to operate it (I coded, my co-founder was a lawyer).

A friend of mine built a very similar product and opened his doors while we were still hesitant, and this happened: http://www.cftc.gov/PressRoom/PressReleases/pr7231-15

Can't you incorporate in an off-shore jurisdiction?

That strategy didn't work for Liberty Reserve, which was in Costa Rica. If Uncle Sam doesn't like what you're doing, he'll find you wherever you are and get you somehow.

https://en.wikipedia.org/wiki/Liberty_Reserve

Not if you want to ever set foot in the US again. If the SEC/CFTC really wants to nab you, they will. There's almost no way to prevent Americans from using your service and once they do you are wide open to any prosecutor worth their salt.

probably super illegal to operate from offshore in the US.

    We won’t work with actual bitcoins or wallets, since they add a lot of complexity and risk without making the article any more interesting.

Actually that is the most interesting part -- how to manage re-orgs & forks is an open question.