("EDD") applies where a client, matter, transaction or business relationship presents a higher risk of money laundering, terrorist financing, proliferation financing, sanctions evasion or other financial crime.
EDD is not a separate process from client due diligence. It is the application of additional measures designed to enable Keystone to understand and manage elevated risk.
Where EDD applies, the responsible lawyer must ensure that sufficient additional information, evidence and scrutiny have been obtained to enable the Firm to understand the client, the matter, the source of funds and, where relevant, the source of wealth, and to determine whether it is reasonable for Keystone to proceed.
The nature and extent of EDD will depend on the risks identified and must always be proportionate to the circumstances of the matter.