Earlier quoted context omitted.
We're going in circles here. Here's the thing: the law looks to intent. If the sole purpose of issuing these things is to evade regulations by coming up with something that's not designated a currency but otherwise operates like one, no amount of jumping up and down and screaming "it's not a currency! don't call it a currency!" isn't going to make it something other than a currency. Courts aren't dumb and they don't…
Most non-currency things can be sold for currency. What makes BAT more similar to a currency than those things?
With a token such as a laundry/car-wash token, an amusement ticket, or a Disney Dollar, you can't get cash back from the issuer. Once you buy them, they're yours forever, unless you can find a third party to give you money for them. The fact that you can (try to) sell them on eBay to a willing recipient doesn't make them currencies.
So I think it comes down to who controls the exchange. If it's a third party with no connections whatsoever to the issuer, then it's unlikely to be considered a currency. But if the issuer is also operating the exchange, or has a connection to the operator, then I think it's going to look a lot more suspect in the eyes of the law.
Again, this isn't legal advice - consult a licensed attorney in your jurisdiction.