Client due diligence, risk assessment, sanctions screening and source of funds enquiries are not one-off exercises undertaken at matter inception and then forgotten.
The Money Laundering Regulations require Keystone to conduct ongoing monitoring throughout the life of the business relationship.
The purpose of ongoing monitoring is to ensure that the Firm's understanding of the client, matter and associated funds remains accurate and that any changes in risk are identified and addressed promptly.
The responsible lawyer is best placed to identify evolving risks because they remain closest to the client and the matter. Responsibility for ongoing monitoring therefore rests primarily with the responsible lawyer.