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Re-thinking de-risking: a systems theoretical approach

Tambe, Noemi; Demetis, Dionysios


Noemi Tambe


Purpose: This paper aims to explain the de-risking phenomenon through Luhmann’s risk/danger model and demonstrate that de-risking should be facilitated and encouraged. Design/methodology/approach: The paper applies Luhmann’s system theory and more specifically his risk/danger model to describe the de-risking phenomenon and identify recommendations to address its consequences. Findings: The paper finds that re-defining risk and the anti-money laundering (AML)’s community’s understanding of it can support key stakeholders’ understanding of money laundering (ML) risk and the way to better address consequences of AML decisions. Practical implications: The paper has implications for the banking and regulatory community in relation to the interpretation of de-risking. As systems aim to minimise their exposure to risk, they should not be prevented from de-risking. Originality/value: This paper aims to move away from a narrative description of AML phenomena and presents a theoretical foundation for the analysis of ML risk. The current response to de-risking which demonises it and aims to prevent it is deconstructed through this theoretical lens.


Tambe, N., & Demetis, D. (in press). Re-thinking de-risking: a systems theoretical approach. Journal of Money Laundering Control,

Journal Article Type Article
Acceptance Date Apr 9, 2021
Online Publication Date Jul 24, 2021
Deposit Date Apr 9, 2021
Publicly Available Date Jul 24, 2021
Journal Journal of Money Laundering Control
Print ISSN 1368-5201
Electronic ISSN 1758-7808
Publisher Emerald
Peer Reviewed Peer Reviewed
Keywords Money laundering; Niklas Luhmann; Systems theory; Decision; Risk; Danger
Public URL


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