As such, the rule would deem the following software and behaviors a primary money laundering concern, meaning that such transactions would end up blocked by centralized intermediaries, and could put an end to the development of privacy software even for non-custodial wallets under the threat of criminal liabilities. These include:
- pooling or aggregating [cryptocurrency] from multiple persons, wallets, addresses, or accounts
- using programmatic or algorithmic code to coordinate, manage, or manipulate the structure of a transaction
- splitting [cryptocurrency] for transmittal and transmitting the [cryptocurrency] - creating and using single-use wallets, addresses, or accounts, and sending [cryptocurrency] through such wallets, addresses, or accounts through a series of independent transactions
- exchanging between types of [cryptocurrency] or other digital assets
- facilitating user-initiated delays in transactional activity