You know that I love MLROs. They are quite possibly my favourite people in the world – apart from Donny Osmond, of course. And Victoria Wood, particularly in “dinnerladies”. I digress. MLROs do a difficult job in adverse circumstances, often with a great deal of resistance and grumpiness from colleagues. So on the whole I ♥ MLROs. But I have to admit that if I were a criminal planning world domination (as they all surely do), I would make sure that I bought myself a really influential MLRO. After all, the MLRO can not only make sure that no SARs mentioning me make it through to the authorities, but he can also adjust in-house procedures to my advantage, so that I am never asked impertinent questions or required to produce any pesky documentation.
What staff may not realise is that it is not obligatory to make SARs to their MLRO. They must make SARs, of course, when they are suspicious, but if they fear that their MLRO has been turned, they are perfectly entitled to make their report direct to the FIU instead. In fact, the MLRO was really only invented as a reporting convenience for staff, so that they didn’t have to hotfoot it with a SAR to their local cop shop – and the role grew from there. So when I am training, I often mention this: if you’re worried that your MLRO is crooked, you can always report direct to the authorities. It gets a laugh, and gives us the chance to talk a bit more about the purpose and use of SARs. But recently a client, herself an MLRO, asked me to take that bit out of the training, on the basis – I’m guessing – that she didn’t want her staff to entertain the possibility of their MLRO being untrustworthy. I can see her point of view – after all, perhaps it is not really a laughing matter – but isn’t informed caution better than blissful ignorance? What do you other MLROs out there think? Am I making fun of your integrity, or should staff be alerted to the possibility of criminal infiltration at the highest levels?