@Kasey Nordeen I don't know what a Wholesaler calls the money they collect on a Wholesale transaction, a Fee, a Commission, Finders Fee, Facilitation Fee? Whatever it's called the DC Code seems to have covered all options by using the language "or other valuable consideration" Unless you're doing it for free there is some form of value being obtained by the Wholesaler period.
You can contact the Real Estate Commission as recommended by @Russell Brazil , with my experience with contract law the language stating "valuable consideration" would be what DC would most likely argue as the violation in a legal matter.
Even with the code in place I will say that I've encountered many Wholesaler trying to conduct transaction in DC, I'm assuming the code enforcement just hasn't caught up to the illegal practice taking place.
Instead of Wholesaling maybe you can propose an enforcement arm to the RE Commission to shut down the illegal Wholesaling and make money that way.