Doesn't the bill state that it only applies to steroidal compounds which are not an estrogen, progestin, corticosteroid, or DHEA?
I think it would be a pretty risky argument to try to tell the DEA that your molecule that is a 2-step derivative of DHEA, marketed towards building muscle like testosterone, doesn't fall under the act because the act says that DHEA is ok. Now, if you were selling straight DHEA and you marketed it as saying it may increase libido, that would be fine.
But you have to remember when the question will be asked. Some guy from the DEA isn't going to call up a company and say hey, quick question, is that molecule you are selling as a prohormone a form of DHEA? Ok, carry on.
You could be getting asked the question in front of a grand jury, who probably isn't going to give a **** about your extrapolating argument about how it is a prohormone with a DHEA backbone that requires 2 conversions in the body to become active. Especially with all of these companies blatantly writing all over the internet how they "convert and become anabolic"
Note - I have not paid attention to any of the recent 2, 3, 5 step prohormones that are floating around today so I don't know if it applies to any or all of them