Good question. The 1960 statute which criminalizes unlicensed money transmitting has three parts. The first is for not having a state license, the second is for not having a federal license, but the third - which storm and SW ended up guilty of - actually doesnt have anything to do with licensing; it criminalizes the known transmission of criminal proceeds and was added later (after the patriot act). This makes sense for when, for example, a licensed business transmits criminal proceeds. They wont be charged with a licensing violation bc they *have* a license, but can still be charged with a 1960 violation under that third part. For Storm and SW the government basically said: we say you are *transmitting* money, but we’re not going to pursue the federal or state licensing violation, we’ll only pursue the transmitting criminal proceeds part. Initially they were charged with the federal licensing violation as well, but that was dropped after the blanche memo.