charging them with conspiring to operate an unlicensed money transmission business and conspiring to violate the Bank Secrecy Act by knowingly failing to maintain a design designed to prevent KuCoin from being used. Adequate anti-money laundering (AML) programs for money laundering and terrorist financing, failure to maintain reasonable customer identity verification procedures, and failure to submit any suspicious activity reports. KuCoin was also accused of operating an unlicensed money transmission business and material violations of the Bank Secrecy Act. Gan and Tang are still at large.