And it's worse. IIUC the money laundering charge is *conspiracy*. So they needed to have the intention of someone using the UI to launder money, and take one concrete step towards it (like writing the code). If such a charge survives, even if a license wasn't needed, that's a problem.

The Netherlands doesn't even have a license system for this, so it's really just about the question whether or not this was (actual, not conspiracy to) money laundering.

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(where "intention" is a bar perhaps as low as "disregard for the risk of")