>>no, it's money laundering even if the funds haven't been procured from criminal activity.
You are wrong.
FINCEN "Money laundering involves disguising financial assets so they can be used without detection of the illegal activity that produced them."
WIKIPEDIA "Money laundering is the process of concealing the origin of money obtained from illicit activities such as drug trafficking, corruption, embezzlement or gambling, by converting it into a legitimate source."
You are wrong.
FINCEN "Money laundering involves disguising financial assets so they can be used without detection of the illegal activity that produced them."
WIKIPEDIA "Money laundering is the process of concealing the origin of money obtained from illicit activities such as drug trafficking, corruption, embezzlement or gambling, by converting it into a legitimate source."
https://www.fincen.gov/what-money-laundering
https://en.wikipedia.org/wiki/Money_laundering