[ChrisLomont]

>Given that it also has legitimate uses,

You're not addressing the point about "(a)(1)(B)(ii), which concerns reporting requirements".

If they cannot meet US law for reporting requirements, then they are breaking the law, right?

[downandout]

No, they are not. They aren’t actively participating in the transactions, and thus have no reporting requirement. Users are not allowed to structure transactions, as it is illegal for them to do so.