I love lawyerspeak. > As such, they have an obligation to register with FinCEN; to develop, implement, and maintain an anti-money laundering compliance program

I love lawyerspeak. > As such, they have an obligation to register with FinCEN; to develop, implement, and maintain an anti-money laundering compliance program Hmm yes, this business which existed to launder money did not implement anti-money-laundering measures, therefore it will be fined.