That loophole comes in the form of Iran's national cryptocurrency. The project was announced a while ago, and seems to bypass the existing ...
source https://www.google.com/url?rct=j&sa=t&url=https://www.livebitcoinnews.com/fincen-sees-irans-national-cryptocurrency-as-exploiting-the-financial-ecosystem/&ct=ga&cd=CAIyGmM2Nzk3ODA2ZWViNjVjODI6Y29tOmVuOlVT&usg=AFQjCNEwPNA2SYvNJsNN9OFDXfHwqTxPkg
