This is why PayPal for the longest time made it really clear that "we are not a bank". So that they wouldn't be subject to those regulations and could suspend accounts and keep the money.
They kinda can.
In other words, you leave the bank-branch with a big sack of cash... And then your car is impounded because you can't prove you're the owner or your license expires, and you'll live in a tent in the woods because landlords can't verify your credit/rental history, etc.
The important part is that they can't just close your account and keep everything.
Meaning the requirement is just Apple or Google account with extra steps.