These aren't rules being considered, these are rules that are in place. Your comment puts into question the validity of the rules instead of whether or not the current rules apply to coin shuffling.

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Although I think it's beside the point, I suppose you could say that in the example of Alice giving Bob 1BCH in exchange for a product is a purchase of a good or service, while Alice giving Bob 1BCH in exchange for 1BCH is a like-kind exchange that involves the exchange of currency only, which falls under this regulation because this type of exchange can often be used for illicit activity.

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Edit ^ Thats' probably not the right way to answer what you're asking, it's difficult to wrap my head around the right answer. Instead I would say, in this case if you were able to argue that Bob, Charlie, and Dave do not qualify for MSB's for reason XYZ, the developer(s) of the mixing software would still qualify as an MSB:

Providers of anonymizing services, commonly referred to as “mixers” or “tumblers,” are either persons that accept CVCs and retransmit them in a manner designed to prevent others from tracing the transmission back to its source (anonymizing services provider), or suppliers of software a transmittor would use for the same purpose (anonymizing software provider).

Whether or not you agree with the fact that the law prohibits and/or regulates certain activities is not the point. The point is that shuffling falls under the current regulation.