Hey Matt,
This came up on the last ILP community call.
The thread may be of interest: Community Call - September 18th, 2019 - #15 by fractal-synapse
(See especially Stefan’s comment on roles of participants)
Stronghold is not Coil’s bank. Stronghold is a digital wallet that creators can use to accept payments from Coil. Coil pays creators for their content using ILP and if those creators are using a Stronghold wallet then Coil settles with Stronghold for all the payments made to their users.
Interledger is a messaging protocol, similar to the protocols used on card networks for payments between PSPs and banks. Once payments have been sent via ILP they still need to be settled. (Each participant in a payment settles with their direct peer.)
As you can imagine this means that anyone one the network that wants to ensure they are complying with regulations must make sure they know what role they are playing (payer, payee, money transmitter) and abide by the regulations that govern that role.
If you peer with someone (accepting and or sending ILP packets from/to them) then you should be confident that relationship doesn’t change the nature of your role on the network.