The CFTC's Binance Case as a Roadmap
Alongside the CFTC's charges against Binance, the United States government is also providing clues about how to operate a compliant offshore crypto exchange. Most of those charges concern compliance problems of one sort of another. And each and every one of them is about an alleged violation of a US law.
But countless financial services businesses operate without regard to US laws and without trouble every day because they do not touch the US legal or financial systems directly.
An alternative reading of the charges is as a map for how to run an offshore exchange the US will not complain about.