Client and Matter Risk Assessment

Every matter must be subject to a ("CMRA").

The purpose of the CMRA is to ensure that Keystone understands the risks presented by the client, the matter and any funds connected to the instruction, and applies due diligence and monitoring measures that are proportionate to those risks.

The CMRA is not an administrative exercise. It is the responsible lawyer's recorded assessment of whether it is reasonable for Keystone to act and, if so, what level of financial crime controls are required.

The CMRA consists of two components:

1. The Risk Questionnaire, completed when the matter is opened; and
2. The Narrative Risk Assessment, maintained by the responsible lawyer throughout the life of the matter.

Both form part of the Firm's compliance record and must be kept up to date.

When completing a CMRA, you should consider the client, the matter, the proposed funds flow and any wider circumstances that may affect risk. Particular attention should be paid to:

• the identity of the client and any beneficial owners;
• ownership and control structures;
• the purpose and intended nature of the instruction;
• the jurisdictions involved;
• the source of any funds or assets connected to the matter;
• whether the instructions make commercial and legal sense;
• whether there are any sanctions, PEP, adverse media or other risk factors;
• whether any aspect of the matter is unusual, unnecessarily complex or inconsistent with your understanding of the client.

You should record not only the facts identified, but also your reasoning. A good CMRA explains why you are satisfied that the matter is capable of proceeding and how any relevant risks will be managed.

A client's existing relationship with Keystone, personal familiarity with the client or a recommendation from a trusted introducer may assist your understanding of the matter but does not remove the need to conduct and document an appropriate risk assessment.

Where any material risk factor, uncertainty or concern is identified, you must record it within the CMRA and follow any applicable escalation procedures.

If the Risk Questionnaire generates a Higher Risk outcome, or if the responsible lawyer otherwise considers the client or matter to present elevated financial crime risk, the matter must be referred to the MLRO for review before proceeding.

The CMRA must remain a live document. If the scope of the matter changes, new parties become involved, the source of funds changes, or new risk factors emerge, the assessment must be updated accordingly.