Different considerations may apply where funds are received solely in payment of Keystone's fees. Payment of proper fees for genuine legal services provided at normal commercial rates will generally engage the statutory adequate-consideration provisions.
This protection should not, however, be treated as automatic or absolute. It may not apply where the fee is disproportionate, where the payment arrangements themselves give rise to concern, or where the lawyer knows or suspects that the services assist criminal conduct. It does not remove any separate reporting, sanctions, or other financial crime obligations.
Lawyers should therefore remain alert to unusual payment arrangements, including payments from third parties, payments inconsistent with the client's known profile or circumstances, or arrangements that otherwise lack an obvious explanation or give rise to concern. Further enquiries may be required in such cases.
If you have any doubt about the source, structure, or circumstances of a fee payment, contact the MLRO.