@dbarabander
The Second Circuit case of Bah, which is binding on the Tornado Cash court, shows why. In that case, the defendant owned a restaurant in New York, would receive cash from customers there, drive it across the river to New Jersey, and send it from his business in New Jersey to recipients abroad.
The defendant had a money transmitting license in New Jersey but not New York, so the government was in a bit of a bind because it was lawful to transmit the money in New Jersey. To try and get around this, the government argued that the defendant driving the funds from New Jersey to New York itself constituted a “transfer” under § 1960(b)(2).