Mixers are not prohibited by law.

18. Based on my training and experience, I am aware the Bank Secrecy Act requires
anyone who owns or controls a money transmitting business to register with the United States
Department of the Treasury. See 31 U.S.C. § 5330(a)(1). I am further aware that federal
regulations issued pursuant to the Bank Secrecy Act define a “money services business,” which
include “money transmitter(s).” 31 C.F.R. § 1010.100(ff)(5). Money transmitters are defined
broadly to include anyone who “accept(s) . . . currency, funds, or other value that substitutes for
currency from one person and . . . transmi(ts) . . . currency, funds, or other value that substitutes
for currency to another location or person by any means,” as well as “[a]ny other person engaged
in the transfer of funds.” 31 C.F.R. § 1010.100(ff)(5)(i)(A)-(B). MSBs are required to register
with FinCEN, a division of the Department of the Treasury, unless specific exemptions apply. 31
C.F.R. § 1022.380(a)(1). MSBs are required to establish and maintain anti-money laundering
programs, to detect and report suspicious transactions, and to collect certain records of customers
and customer transactions. I am further aware that bitcoin “mixers” or “tumblers” such as
ChipMixer are considered to be MSBs under federal law. See U.S. Department of Treasury
FinCEN Guidance, Application of FinCEN’s Regulations to Certain Business Models Involving
Convertible Virtual Currencies, FIN-2019-G001 (May 9, 2019), at 19-20.