“To the extent there are U.S. touch points, or U.S. persons involved in such transactions, crypto companies could face enforcement from FinCEN, OFAC and/or the U.S. Department of Justice, depending on the activity at issue and whether any U.S. laws were violated,” he said. “Even without a violation, an investigation can be incredibly taxing on resources and distracting to leadership. As a result, crypto companies may wish to steer clear of mixers, to the extent possible.”
