In any case as your lawyer might tell you: if the origin is illicit it is money laundering. If the origin is not illicit then its not money laundering.
The irony being that it is the onus of the accuser to determine the origin, and if you do it right that is not possible to know in any scenario. Typically money laundering then is a tacked on charge, after other clear evidence is already known, to help ensure a conviction.
But really at this point, its probably better if your public resources weren't spent on flagging transactions in the first place, and if the private sector was not burdened with doing this work for the state.