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Direct profit from transactions is not required to be an MSB
An often discussed aspect of Bitcoin mixers or privacy tools is that a fee for their usage is directly paid in the transaction where privacy is gained. But Tornado Cash did not operate this way, and no direct fee was paid by a user in their transaction to the Tornado Cash founders.
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But the DOJ makes it clear here that direct profit from transactions is not a requirement for being considered a money transmitter.
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