I'm confused how the connection was made between "here are our guidelines for suspicious activity" and "self custody is outlawed"
> creating and using single-use wallets, addresses, or accounts, and sending [cryptocurrency] through such wallets, addresses, or accounts through a series of independent transactions
One could argue that's how normal Bitcoin wallets work. The addresses are deterministic based on your passphrase (or derived private key). The addresses don't need to get reused because there's no real value in doing so, and no real cost of just using a new address each time.
Though yes--even if that's the exact meaning and design, presumably one could still use the simpler wallets that DO just reuse the same address over and over. And obviously that'd reduce privacy quite a bit.
Because just about all those practices are what reasonable users of the protocol would do, and making your transactions 'suspicious' is synonymous with all the big players refusing to deal with you. It's a way of prohibiting behaviour outside the force of law, which is even more insidious.
It can be hard to figure out exactly what is outlawed with banking interactions. It seems a lot of the KYC/AML stuff is based on industry best practices and guidelines. There's no law you need a state ID with address to open a bank account, but when I tried to open up a bank account without an address I found it basically impossible. The bank will then cite that these practices are what they're held to as law, because the law itself is vague and relies on more nebulous customs.
So what is called "guidelines" one day becomes legally binding later with no act of congress.
Unfortunately there's a massive swath of mere guidelines and regulation that end up having legal binding. For instance, a Navy sailor was recently sent to jail for 20 years for having gun parts that were cut up the wrong way, the "wrong way" being the right way with previous mere guidance and the wrong way apparently being the fact that some time since then the guidance changed but not the law.