Lawyer snark is a special kind of snark.
“Setting aside FinCEN's own apparent confusion about whether CVC mixing is a transaction, a service, a business, or a specific business entity, when FinCEN does attempt to define the "class" of transactions that it considers to be CVC mixing, the Mixing Transaction NPRM's definition of "mixing" is extremely broad and includes numerous activities routinely conducted by legitimate users as a matter of routine safety precautions in online transacting in CVC.”
https://blog.samourai.is/our-response-to-fincen-on-proposed-rules-for-bitcoin-mixing/