[tromp]

Part A:

> provides check cashing, currency exchange, or money transmitting or remittance services

says that Samourai is a money transmitting business iff they provide a money transmitting service. Part B:

> accepting currency, funds, or value that substitutes for currency and transmitting the currency, funds, or value that substitutes for currency by any means

says that they must be accepting currency/funds/value, which they don't appear to be. They only accept instructions from each user for how to spend funds to themselves.

[JumpCrisscross]

> provides check cashing, currency exchange, or money transmitting or remittance services

They're exchanging currency. (SWIFT is just a messaging service, for example.)

[cryptonector]

That's right, a crypto mixer that affords true privacy (except relative to the mixer itself) w/o additional controls (e.g., transaction limits comparable to practical limits on cash transactions) is definitely a money laundering enabling capability.

Whether one can conclude that the people running the crypto mixer are engaging in criminal activity will depend on the text of the relevant statutes, though I'm pretty sure those will be fairly airtight.