I have another quick question for clarification from the Minister. Clause 19 deals with reporting obligations of relevant institutions. It refers to the situation when a relevant institution knows or has reasonable cause to suspect that someone is a designated person, and so on. The Minister has explained the steps that will be taken to publicise a designated person—through the Treasury website and through disseminating that information on to financial institutions—but the concept of an institution knowing the necessary information is open to challenge. What happens within the chain of command if a junior member of staff within a financial institution has reasonable cause to suspect a person, but people further up the food chain do not, or vice versa?
I am sure that the hon. Lady will remember from her experience of working in the financial services sector—I certainly know from my experience of working with a professional services firm—that procedures are in place, around money laundering, for example. Such procedures ensure that suspicious activity is reported further up the food chain, as it were, within financial institutions.
We expect institutions to have processes in place to ensure that information is made known—first within them, and then to the Treasury. We expect that where the reporting business knows or suspects that a customer is a designated person, it must provide details of the nature and the amount or quantity of funds, or economic resources held by it for the customer at the time when it first had knowledge or suspicion. We expect the institution to have the proper the processes in place to identify relevant situations.