Liberty Reserve did not take or make cash payments directly and instead used "thirdparty 'exchangers,'" according to the indictment. These exchangers would take and make payments, and then credit or debit the Liberty Reserve account, allowing Liberty Reserve to avoid collecting any banking information on its clients and not leave a "centralised financial paper trail," the indictment said. The exchangers, the indictment said, "tended to be unlicensed money-transmitting businesses without significant government oversight or regulation, concentrated in Malaysia, Russia, Nigeria and Vietnam."

The people who accepted Liberty Reserve's currency were "overwhelmingly criminal in nature," according to the indictment. "They included traffickers of stolen credit card data and personal identity information; peddlers of online Ponzi and get-rich-quick schemes; computer hackers for hire; unregulated gambling enterprises; and underground drug-dealing websites," according to the indictment.