Collection and retention of CDD records

The Firm operates a centralised client due diligence process. The Clients Team is responsible for obtaining, reviewing, maintaining and retaining identity and verification records in accordance with the Firm's procedures.

This includes:

• collection and retention of identity and verification documents;
• electronic identity verification;
• screening for sanctions, PEP and adverse media results;
• maintenance of central CDD records; and
• ensuring the Firm's records remain complete and up to date.

Lawyers should not maintain separate collections of identity documents outside the Firm's approved systems. Where identity documents or other verification records are received directly from a client or third party, they should be provided to the Clients Team promptly for central retention and review.

Once the Clients Team has received the documents, any duplicate copies held in email, local storage or the matter file should be deleted unless there is a documented legal or operational reason for retaining them. The Clients Team should ordinarily remain the central custodian of identification documents.

The Clients Team's responsibilities are administrative and evidential in nature. They do not replace the responsible lawyer's obligation to understand the client, the matter or the associated risks.

Accordingly, responsibility for the following remains with the responsible lawyer:

• understanding who the client is and why they have instructed Keystone;
• understanding ownership and control structures;
• satisfying themselves that any individual instructing Keystone has appropriate authority to do so;
• understanding the purpose and intended nature of the matter;
• assessing client and matter risk;
• understanding and assessing source of funds and, where required, source of wealth;
• ensuring the instructions, transaction structure and funds flow make commercial and legal sense; and
• conducting ongoing monitoring throughout the life of the matter.

The responsible lawyer must not assume that completion of identity verification or sanctions screening means that a matter is suitable to proceed. Identity verification confirms who a person is. It does not determine whether Keystone understands the client, their instructions, the source of funds or the risks associated with the matter.

CDD must be reviewed and refreshed where required by the Firm's procedures, including where there has been a material change in ownership, control, identity, authority or risk, where existing information is no longer reliable or adequate, or where a new instruction follows a period of inactivity specified in the applicable CDD Checklist.

Where the responsible lawyer becomes aware of any material change to a client's ownership, control structure, authority to instruct, legal status or other information relevant to the Firm's CDD records, they must notify the Clients Team promptly so that the Firm's records can be updated where necessary.