But in this case they are setting up a bank that has the ability to facilitate certain banking practices that would be difficult to accomplish without a complic

But in this case they are setting up a bank that has the ability to facilitate certain banking practices that would be difficult to accomplish without a complicit bank. As such, no person, whether a criminal or not, would be able to commit these crimes without the help of the bank acting as law enforcement agent. The only way it would not be entrapment with regards to the illegal banking would be if they could show that there are other non-law-enforcement run banks that were available to make these facilities available to the defendant. If other banks have mechanisms in place to prevent these banking crimes in the first place, then you couldn't expect that the defendant could have committed them without the assistance of the government agent. However if they learned information about other criminal activities through this, then those activities would not be subject to a defense of entrapment. So go ahead and charge them on drug trafficking. But the laundering charges look like entrapment to me. Not a 100% shut and closed case, because it is a bit subjective, but I would expect any defense to have a good chance with it.