Nah, laws are unclear. They should have pushed back on the interpretation, in particular, the part about withdrawing to mixing services is really bad as it means sending funds from Swan to others is risky.
Doesn't seem like it's a matter of Swan complying or not complying with laws. The problem is that they have banking partners. That's the weak link. Swan can only be as freedom-maximalist as their banking partners will allow. Regardless of the what the letter of the law says. They don't operate in a vacuum.
Set coward to max...engage!