Financial crime prevention is a core legal and professional obligation. Keystone will not knowingly facilitate financial crime or undertake work that is prohibited by law.
Keystone's financial crime controls do not operate in isolation. The Firm's Practice-Wide Risk Assessment reflects international, national and sector-specific assessments of financial crime risk, including guidance from FATF, the UK Government's National Risk Assessment and the SRA's Sectoral Risk Assessment. The Client and Matter Risk Assessment is the mechanism through which those broader risks are considered and applied to individual clients and matters.
We manage the risk of the Firm being used for financial crime through proportionate, risk-based controls.
Financial crime includes:
The Firm's governance arrangements, risk appetite and mandatory control framework are set out in the Anti-Money Laundering and Sanctions Policy ("AMLAS Policy"). The AMLAS Policy is supported by a suite of anti-financial crime policies and procedures dealing with specific risk areas, including PEPs, reporting discrepancies, sanctions, tax evasion, fraud and internal reporting obligations.
It should be read alongside the Firm's:
These documents form part of Keystone's overall anti-financial crime framework and must be read together. Where the requirements differ between England and Wales and the Isle of Man, you must follow the procedure applicable to the Keystone entity through which the matter is conducted