“To the extent there are U.S. touchpoints, or U.S. individuals concerned in such transactions, crypto firms might face enforcement from FinCEN, OFAC, and/or the U.S. Division of Justice, relying on the exercise at situation and whether or not any U.S. legal guidelines had been violated,” he mentioned. “Even with out a violation, an investigation might be extremely taxing on assets and distracting to management. Consequently, crypto firms might want to keep away from mixers, to the extent attainable.”