Approval requirements

Before Keystone establishes or continues a business relationship involving a PEP, family member or known close associate, senior management approval must be obtained in accordance with the Money Laundering Regulations and the PEP Policy. No new PEP relationship may proceed until the required approval is recorded.

The responsible lawyer should ensure that:

• the relevant PEP relationship has been disclosed;
• the associated risks have been assessed and documented;
• source of funds and source of wealth enquiries have been completed to an appropriate standard; and
• any required approvals have been obtained before the matter proceeds.

Approval should not be treated as a substitute for proper enquiry. The purpose of approval is to ensure that the risks have been identified, assessed and considered at the appropriate level.

PEP relationships require enhanced ongoing scrutiny throughout the business relationship.

The responsible lawyer should remain alert to:

• changes in public office or influence;
• changes in ownership or control arrangements;
• changes in source of funds or source of wealth;
• unexpected transactions or instructions;
• emerging sanctions, corruption or adverse media concerns; and
• any other circumstance that may alter the Firm's assessment of risk.

The existence of a PEP relationship should be taken into account whenever the Client and Matter Risk Assessment is reviewed.

Clients and matters subject to EDD must remain subject to enhanced ongoing monitoring in accordance with section 4.1.33.