Client Due Diligence

("CDD") enables Keystone to understand who it is acting for, who owns or controls the client, and the purpose and intended nature of the business relationship.

CDD is not simply an identity-checking exercise. Its purpose is to provide sufficient information for Keystone to understand the client, assess risk appropriately and identify circumstances that may require further investigation or escalation.

The responsible lawyer must ensure that Keystone has sufficient information to:

• identify the client;
• verify the client's identity where required;
• identify and verify beneficial owners and persons exercising ownership or control where required;
• understand who is authorised to instruct on the client's behalf;
• understand the purpose and intended nature of the instruction; and
• determine whether the information obtained is consistent with the proposed matter.

The level of due diligence required depends on the circumstances of the client and matter. Higher-risk scenarios may require additional enquiries, enhanced due diligence measures or MLRO approval before the matter can proceed.

The specific evidence required for each client type is set out in the applicable Checklist. These requirements may change from time to time and lawyers must always use the current version of the relevant checklist.