I have read FinCen guidelines and not being a lawyer its not clear to me. In one part it seems to say its fine but in another it appears to be able to fit into

I have read FinCen guidelines and not being a lawyer its not clear to me. In one part it seems to say its fine but in another it appears to be able to fit into "exchanger" I find it odd to have not found an easy clear answer to this at this point.