What if we redesign it so the customer’s own wallet signature releases the funds?

It helps one factor of one test and does not make the business unlicensed-eligible. If your servers still submit transactions and cover fees, the customer still does not interact directly with the payment system. Receiving the sender’s value into a contract your company deployed, administers, and dispute-resolves is still acceptance for transmission. Any fiat leg remains money transmission under classic pre-crypto law. And an operator-run application performing transmission remains a transmitter regardless of which key signs last. Redesigning the trigger is good risk engineering inside a licensed structure. Done instead of licensing — especially after asking the question — it reads to a regulator as structuring around the statute.