Did FinCEN exceed its statutory authority by interpreting 'funds' in 31 U.S.C. § 5330 to require registration of virtual currency businesses before congressional amendment in 2021?

Did the federal agency FinCEN exceed the authority granted in 2001 by Congress in 31 U.S.C. § 5330 to regulate money transmitting businesses when FinCEN interpreted one word in that statute – “funds” – as authority to require sellers of bitcoin and other virtual currencies prior to 2021 to register with FinCEN, when virtual currency was not invented until 2008 and when Congress did not amend the statute to capture virtual currencies until 2021, after they had become financial instruments of great political and economic significance?