Not quite. Cohen lied to his bank about what the money would be used for. Befroe trump paid him back, cohen used his own money, which he grabbed by getting a home equity loan. He lied to the bank about what he would use the money for.
That's bank fraud. Also, he lied to his bank when he transferred the money to clifford. Another fraud.
The same chain holds true when trump, though lawyers and bankers, paid cohen back, in increments.
All of that is illegal if you don't honestly disclose where the money is going and what it is being used for. Breaking the payment down to avoid detection is a form of money laundering.
So "even if" the source of the money was clean, the delivery mechanisms constitute bank fraud, money laundering, and conspiracy.