Yes. In practice money laundering is essentially anything that involves money that the government has not explicitly approved. Several E-currency exchangers and services have been busted in USA and charged with money laundering, even ones that were apparently taking some efforts to follow the law. You would really need to have solid brass balls to operate a bitcoin exchange in USA unless you get written permission from the government saying that you are allowed to do so (probably in the form of some license) + keep detailed records on each of your customers + fully comply with suspicious activity reporting laws etc etc etc.