Higher risk matters

Higher-risk matters require greater levels of scrutiny.

Where enhanced due diligence has been applied, lawyers should continue to consider whether:

• the original basis for the enhanced risk rating remains accurate;
• any conditions or mitigations remain appropriate;
• source of funds and source of wealth information remains reliable;
• any additional approvals remain valid; and
• any new concerns should be escalated.

The level of monitoring should remain proportionate to the risks presented.

Higher-risk matters are also subject to the Firm's formal enhanced-monitoring process overseen by the MLRO. The responsible lawyer must respond promptly to periodic review requests and confirm whether there have been changes to the client, ownership, instructions, parties, jurisdictions, funding arrangements, source of funds or any other matter relevant to risk. Reviews will be conducted at the frequency determined by the MLRO and, unless otherwise directed, at least every three months while the higher-risk classification remains in place.