But also irrelevant to the Dutch case; these are US sanctions. Though perhaps there's an indirect case for laundering the proceeds of a crime (violating sanctions law of a befriended country). In any case this is the first time I hear about it. Pretty sure the Dutch prosecutor would have brought this up in the courtroom full of journalists if she knew about it at the time.
Discussion
Didn't fincen write in like 2014 that non-custodial services don't need this license? Or was it more ambiguous? 