The law passed in 1986 to "combat organized crime and drug syndicates" is today applied to cases barely recognizable as what was intended. A violation of virtually any federal statute, and a host of state ones that involves the generation of proceeds (and what non-violent crime doesn't?), can be converted into the crime of money laundering as soon as the defendant engages in a "financial transaction" with the money. Whether the "financial transaction" is isolated from or incidental to the underlying crime makes no difference. A financial transaction can be as simple as depositing the money in a bank account, or buying a loaf of bread and a quart of milk!

Lawyer Opinion

The two most important laws governing money laundering in the U.S. are the Bank Secrecy Act, as amended (“BSA”)[13] which imposes extensive record keeping and reporting requirements on financial institutions in order to supply law enforcement with evidence of financial transactions and the Money Laundering Control Act of 1986 (18 U.S.C. 1956, 1957) precludes circumvention of the BSA requirements by creating criminal liability for individuals who conduct monetary transactions knowing, or with reason to know, that the proceeds involved were obtained from unlawful activity.

The BSA requires financial institutions to file Currency Transaction Reports (“CTRs”) with the U.S. Treasuring reporting deposits, withdrawals, and exchanges of more that $10,000 of currency. These reporting requirements as well as the obligations to implement Know Your Customer (“KYCs”) guidelines on banks have grown substantially over the last few years and the banking industry has consistently opposed them as unduly burdensome, expensive, and ineffective. Recent events at Citibank, BankBoston Corp, and BONY support, at least to some extent, the last of these criticisms.

Money laundering

I didn't find a link that is specific to the implications of withdrawal but it is my recollection and understanding that the proceeds of a withdrawal used for unlawful activity is equal to a deposit of money derived from unlawful activity. They are both financial transactions and if an unlawful act is involved it falls under the statute.

I'm not a lawyer and I didn't stay at a Holiday Inn Express last night but I am pretty sure I am right.

Makes looking at your library card transactions sound tame huh?