If that is the case, participating in the Zerocoin network itself would be a crime. I don't think this is going to go anywhere. And if it does, then hope that the Secret Service doesn't catch you even touching this stuff...
Since withdrawing money from an ATM is not money laundering, it works.
What makes it anonymous is that anyone can now start a 'bitcoin account' with purely unconnected zerocoins without any AML paperwork to go through just like a real life equivalent of dumping stacks of cash at your no questions asked numbered bank account service.
Since BTC is expected to be regulated like a currency
[1] http://fincen.gov/statutes_regs/guidance/html/FIN-2013-G001....
Would they not try to claim that using Zerocoin is, in effect, making you an independent exchange? Or are you only an exchanger when going from Bitcoin to USD?
An exchanger is a person engaged as a business in the exchange of virtual currency for real currency, funds, or other virtual currency.
There is this clause, but it only refers to businesses.
Might be difficult, there's no market there. One Zerocoin is one Bitcoin in value by definition. It's not an exchange to convert dollars into cents, so it would be hard to argue this.
If you participate in the Zerocoin network, you can therefore issue Zerocoins (in exchange of bitcoins), and redeem Zerocoins for bitcoins.
Its like any other law, except the Secret Service is especially hard on money launderers.