The illegal thing is breaking the traversible chain of provenance of funds. All money transmitters by law MUST keep those records as a condition of being licens

The illegal thing is breaking the traversible chain of provenance of funds. All money transmitters by law MUST keep those records as a condition of being licensed to engage in the business of money transferance on the behalf of a third party. If you came into possession of a money transmission framework, and you ran accounts for someone else without doing KYC, or integrating with OFAC, and were found to have transacted in a way that facilitated illegal activity or sanctions violation, you are now strictly liable for those violations. If you wish to participate in the act of moving money, you must make law enforcement's job tractable. It is a pre-requisite of the business vertical in the United States. In brass tacks plain, layman english: The United States Financial System is a grafted on appendage of Law Enforcement. Every legal department in a financial services company is responsible for setting up a dedicated division responsible for facilitating an integration with Law Enforcement. Is that clear? I'm not making any judgements as to whether it should be that way, mind, just telling it how it is. Mixers were never practically legal in any way shape or form. They just weren't explicitly stated by the name "Mixer" as being illegal by statute or Administrative dicta. Not a lawyer, just been part of implementing and auditing my fair share of systems.