Why would the "other stuff" need to be offchain?
I dunno the US legal priorities but in Europe I dont think anyone cares if the ingame purchased tokens are backed by a blockchain or not. Tokens are just tokens. It's important too have this clear before releasing anything ofcourse. I dont know the current state.
Got the feeling Ive been speculating too much, let me remind it is just my idea of how thing could work.
Also Ionomy is not the only crypto project that's monetizing ingame tokens backed by crypto blockchain.
The blockchain itself is not so much the issue, except they're not really using it for anything. I don't know if it needs to be off-chain, just stating the fact that it IS almost entirely off-chain - ionomy, electrons, etc - nothing to do with the blockchain AFAICT.
The point is, they collected funds (converted into USD apparently), they call the bagholders "investors", they encourage to keep the funds on their website, they solicit (or at least their surrogates do) investments promising "profits", and they expect to make it big. Something's gotta give. They will have to start KYC-ing the bagholders and filing paperwork with the SEC, or they will have to cut the "investment" part off completely and become just a points/rewards system of some sort. Or stay irrelevant forever, I guess that's always an option.