Well not really. The problem is, even if you are based OUTSIDE of the US, how do you accept USD deposits. And how do you send them when they are withdrawn.
That's why Mt.Gox had trouble in the US, they still had accounts there, even though they aren't based there.
So, how does an exchange get around that?
And why do you even need to accept USD?...hell I've been in btc from early on, never seen or touched a USD in my life. Simple don't trade in USD like 95% of the worlds population
simple, USD has to be wired out the country to be exchanged into BTC.
I guess you have never heard of USD denominated checking accounts in non-USA based banks have you... they have been around for decades.