I wonder if instead the usb sticks had empty wallets, would this business be legal? Going a step further, in addition to the empty wallet, if the seller offered

I wonder if instead the usb sticks had empty wallets, would this business be legal? Going a step further, in addition to the empty wallet, if the seller offered a credit/iou of any crypto of the buyers choice (a bit like a visa gift card), where the seller could choose to excersise or claim the credit at any time (or never), I wonder if structuring it like that would still require a msb license etc..