At this point you wonder if he made a deal with someone.
Close up shop, and we won't prosecute you for anything bitcoin related. We want you shut down. Keep their money and we won't prosecute you criminally for it either. You can just take a few civil suits, declare bankruptcy and have a blast with all your cash.
That sounds pretty realistic based on the way he is holding everyone's money.
For the sake of argument, if we assume for the moment that Roman is an honest and trustworthy person who is legitimately interested in getting everyone's USD balances back to everyone . . .
I'm curious, what bank would allow you to open an account if you informed them that your plan was to deposit a single check in excess of $500,000 (could it be in excess of $1 million?), then split that balance up into many ACH transfers over the course of a few days, then close the account?
He's holding a check (a piece of paper IOU that has a dollar amount written on it) and somehow he needs to find a bank that will allow him to open a business account for a defunct business that will close it's account a few days latter?
I'm curious how he's going to solve this.
Would you be willing to do this if there was a good possibility that the bank would be forced by FinCEN to close your accounts on you?
Are you sure that your bank would be willing to participate in this transaction?
I suggest talking with your bank, letting them know exactly what you intend to do, and why, and then if the bank is willing to cooperate and can assure you that your account will not be closed due to this activity, contact Roman and/or his lawyer.
I suspect you will find that your bank will not be as cooperative as you think they will.