IMO, adding an extra hop is an obvious transaction pattern and the next step is a rule against that. But yes, these are work arounds.
I remember back in the day, before easy mixing, to wash coins, I used to move a balance to a gambling wallet, play a little, and then withdrawal. To effectively execute this, FINCEN is literally going to have to create a rule where you can prove above-the-board provenance for the entire history of a balance, and even then, there is lightning.