The Money Laundering Reporting Officer

Regulated firms appoint a Money Laundering Reporting Officer (MLRO), the person responsible for receiving internal reports of suspicion from staff, deciding whether to escalate them as a formal SAR to the National Crime Agency, and overseeing the firm's anti-money laundering compliance more broadly.

If you have a genuine suspicion, your responsibility is to raise it internally, through your organisation's defined process, usually to the MLRO or a nominated deputy, promptly and without alerting the customer. What happens after that, the formal reporting decision, sits with the MLRO, not with the individual who raised the concern.