Ten years ago this article was published and although it is USA centric it still resonates with me.
Article from Lanier Saperstein, Geoffrey Sant & Michelle Ng, The Failure of Anti-Money Laundering Regulation: Where is the Cost-Benefit Analysis? (2015).
Available at http://scholarship.law.nd.edu/ndlr_online/vol91/iss1

One comment that I agreed with was ‘the regulators have been punishing the banks not because of any actual money laundering, but rather because the banks did not meet the regulators’ own subjective vision of the ideal anti–money laundering or counter–terrorist financing program. However, no one has attempted to show that the supposedly ideal vision of an anti–money laundering or counter–terrorist financing program would actually be more effective than the programs the banks have in place.’

On the subject of “De-Risking”, the article suggests that “Regulators have unintentionally made it harder to catch financial crimes, increased opportunities for money laundering, and strengthened criminal networks”.

The article concludes “Before regulators impose policy choices upon banks, they should have a valid basis for doing so. Before regulators push “higher” standards and increased spending upon banks, they should analyse whether those efforts actually reduce financial crime, and if so, whether that benefit justifies the costs”.

Still relevant food for thought today isn’t it?