Keystone's approach

Keystone will only receive or transfer client money where it is properly connected to an underlying legal service being provided by the Firm. The Client Account must never be used as a banking facility. Whenever funds are received into the Client Account, lawyers should understand:

• who is providing the funds;
• why they are providing them;
• the relationship between the payer, the client and the matter;
• the source of the funds being transferred;
• whether the funds and payment arrangements are consistent with the lawyer's understanding of the client and transaction; and
• why there is a legitimate reason for the Client Account to be used.

The fact that a client, introducer or third party requests a particular payment arrangement does not mean that Keystone is obliged to facilitate it. Where the rationale for receiving or transferring funds is unclear, guidance should be sought before any money is received or moved.

You must give the Accounts Team sufficient information in advance to identify the expected payer, amount, currency and purpose of material incoming funds. If the payment received differs materially from what was expected, the difference must be explained before the funds are transferred or applied.