Origin

Keystone has implemented , the Firm's AI-assisted source of funds assessment tool. At the current time this tool is only available to Residential Property colleagues, a firm-wide rollout is coming soon.

is available through Keyed-In as a dedicated tab within the relevant matter and is designed to assist lawyers in evaluating source of funds and source of wealth information.

should be used:

• for any proposed incoming payment to the Client Account of £10,000 or more; and
• wherever higher-risk factors are present, regardless of value, unless the MLRO expressly agrees that an alternative documented assessment is sufficient.

assists lawyers by analysing information and producing a structured source of funds assessment. It does not replace the responsible lawyer's judgement.

Where is used:

• lawyers must review the output critically;
• lawyers must satisfy themselves that the conclusions reached are reasonable;
• any concerns, inconsistencies or omissions should be investigated;
• supporting evidence should be reviewed where appropriate; and
• the lawyer's own assessment and rationale should be documented on file.

Lawyers will receive notifications and reports from as part of this process. These should be reviewed promptly and considered alongside all other information available to the lawyer.

You must not treat an notification as informational only. You must review the assessment and supporting evidence, address any questions or flags raised and record your own satisfaction in an appropriate note on the matter file before the relevant funds are accepted or applied.

The fact that has produced an assessment does not mean that Keystone's obligations have been discharged. Responsibility for the final assessment remains with the responsible lawyer.