My bet is that their new issuances are essentially Hawala between US VC funds: you deposit $20 million w/o moving it from your own account.
Bob runs a well-known VC fund. He wants to buy $20 million of Bitcoin. Bitfinex says they can do that but that only way in/out is tether.
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Bitfinex tells Bob "We trust you. Keep that $20 million on hand. We will give you $20 million tether. You have to promise to buy some back."
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"We know you don't want to be an exchange, so you don't have to buy *ANY* tether. You just have to buy it at par from *another VC fund*"
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