Payments into the Client Account

In order to ensure the smooth operation of the Client Account and legal compliance, you should note the following:

1. We can only accept funds into the Client Account where you assess the risk of the related matter to be low. If you have any concerns at all about the client or the prospective paying party, then you must contact the Director of Operations and Compliance before any funds are sent to our Client Account. Concerns that you must consider include: links to money laundering, terrorism and generally the source of funds or wealth not being lawful or legitimate. If such concerns arise later, then you must report them to the Director of Operations and Compliance immediately.
2. Monies can be paid into the Client Account by electronic payment (preferred) and by posting a cheque (payable to Keystone Law or Keystone Law Limited) to us.
3. We cannot accept cash, either directly or paid directly over the bank counter.
4. Clients must not pay cheques directly into the Client Account over the bank counter.
5. Funds should not be paid into the Client Account during the Grace Period.
6. Use of the Client Account should be at your invitation. Do not give out details of our Client Account until the matter has been fully set up.
7. The Client Account is only for funds incidental to our legal work.
8. The client must complete our AML checks before the Client Account is used.
9. If you are a lawyer based in the UK, then third parties may transfer funds into the Client Account, although the name and address of each third party should be recorded on your file along with a reason why a third party has paid funds into our Client Account. If you have any suspicions as to the probity of the transaction or the paying party, then you should call the Director of Operations and Compliance immediately.
10. If you are a lawyer based in the Isle of Man, third parties may transfer funds into the Client Account by prior arrangement only. Once it is clear that a third party wishes to use our client account, we must then identify them to the same standard as we identify our clients. We also need to know the reason why a third party wishes to pay funds in to our Client Account.
11. The Cashier should be notified in advance of any electronic payment into the Client Account using our Client Funds Expected tool. The Cashier will need to know the client/matter reference, the amount in question and the reason for the anticipated deposit. You should ask the client to quote our client/matter reference when making payment.
12. Orphan funds (i.e. funds from an unknown source) in the Client Account will be placed into a suspense account. The Cashier will attempt to identify the owner of the funds and may send a firm-wide email to this effect. We are obliged to return funds which remain unclaimed after 21 days to their sender.
13. Confirmation of receipt of funds will be emailed to all the lawyers working on the relevant matter. The Client Ledger in Keyed-In will also be updated.
14. If you have any concerns at all as to the legitimacy of funds, you should consult a Director, wherever possible, before they are sent to our Client Account.