"Would they not try to claim that using Zerocoin is, in effect, making you an independent exchange?" Might be difficult, there's no market there. One Zerocoin

"Would they not try to claim that using Zerocoin is, in effect, making you an independent exchange?" Might be difficult, there's no market there. One Zerocoin is one Bitcoin in value by definition. It's not an exchange to convert dollars into cents, so it would be hard to argue this.