How about an exchange site that facilitates contact between buyer and seller?
As in, no bitcoins or cash is kept in the websites "account" (Like Mt Gox) - rather you have a list of sell orders that sellers want to sell their bitcoins at, and a buyer comes along - picks a sell order that they like - and then the website goes "Here's their contact details... get hold of them and figure out how to exchange".
That should have no legal obligations should it - I mean after all it's just an ebay for bitcoin?