When friends come to visit us in Cambridge, I always warn them to get the fancifully-named Cambridge Cruiser trains – the non-stop ones – rather than the more leisurely stopping service which takes in the delights of Harlow Town, Elsenham and Audley End. The benefits of the Cruiser are manifold: it’s quicker, it’s more relaxing, and you know exactly where you are at all times (if you’ve stopped, you’re in Cambridge).
I have always considered this analogous to suspicion reporting lines within regulated institutions. If you have a suspicion, you should report it directly to your MLRO – and not take in the scenic detours via your line manager, department head, branch manager or anyone else. It is an exception to almost everything else you might do, which has a strict hierarchy of decision-making. But at a recent presentation someone questioned this – and not for the first time. The MLRO would be overwhelmed, they contended, and so it is only right that the line manager (in this case) should cast an eye over every suspicion to weed out the ones that are being made only because of the inexperience or ignorance of the reporting individual. It was a persuasive argument, but one that I fear lacks the comfort of supporting legislation. As I see it, no-one except the nominated officer and his approved deputies has the right under money laundering legislation to filter suspicion reports in this way. And if it all goes pear-shaped, it is the nominated officer who will be held responsible – even if it was someone else what done it.
I have always been fond of my Cambridge Cruiser reporting analogy, but what do you think? Are most of you requiring staff to report directly to the MLRO, or is the stopping service much more common than I imagine? And how do those manning the intermediate stops along the way – and indeed the ultimately-responsible nominated officer – feel about their exposure under the legislation?