From the DOJ link.
During this time, Schaback allowed customers to open accounts and trade on Paxful without gathering sufficient know-your-customer (KYC) information; marketed Paxful as a platform that did not require KYC; presented fake AML policies to third parties that he knew were not, in fact, implemented or enforced at Paxful; and failed to file a single suspicious activity report, despite knowing that Paxful users were perpetrating suspicious and criminal activity.
What they don't mention is how many warning they got or if Ray Youssef did anything to protect himself.
As a result of his failure to implement AML and KYC programs, Schaback made Paxful available as a vehicle for money laundering, sanctions violations, and other criminal activity, including fraud, romance scams, extortion schemes, and prostitution.
Does not mention anyone else within the company, so if he changed the direction of how it operated or the way it worked after he came into full control might also play a factor.
i.e. Youssef was 'working' on it but left before anything was implemented.
It's odd that nobody else was mentioned or charged (as of now) so it kind of looks like he was pushing Paxful to operate that way.
-Dave