Keystone does not rely on client due diligence undertaken by another person for the purposes of Regulation 39. Information and documents may be provided by another law firm, accountant, bank, trust and company service provider or other professional adviser, but Keystone will assess that material itself and remains responsible for satisfying its own CDD obligations.
The involvement of another regulated professional may affect the nature and extent of the checks required, but it does not remove the need to understand the client, ownership and control, authority to instruct, the purpose of the matter and any relevant source of funds.