You must familiarise yourself with the Firm's Anti-Money Laundering and Sanctions Policy and Internal Reporting Procedure.
Where you know or suspect money laundering or terrorist financing, you must make a formal internal report without delay using the prescribed reporting form on Keyed-In. Concerns relating to sanctions, proliferation financing, fraud, bribery, tax evasion, or other financial crime must be escalated without delay using the applicable procedure or, where uncertain, directly to the MLRO.
Lawyers are encouraged to seek guidance at an early stage from the Deputy MLRO or Geoff Kermeen as MLRO for Keystone Law (Isle of Man) Limited. An email, Teams message or telephone call will be treated as a request for guidance and not as a formal internal report unless the MLRO expressly confirms otherwise. Requests for guidance are not formal reports and do not replace the obligation to make a report where the reporting threshold has been met.
Reports submitted through the prescribed process will be reviewed by the appropriate MLRO, who will determine the Firm's response and whether any further reporting obligations arise.
Lawyers must not disclose any suspicion, report, or related investigation to a client or third party without guidance from the MLRO.
Legal professional privilege must always be considered. If information may be subject to legal professional privilege, contact the MLRO or Deputy MLRO immediately and do not make your own determination as to whether the information should be included in a formal report. The need to consider privilege must not result in the concern being ignored or left unaddressed.
Once a formal report has been made, or the MLRO directs that work should pause, you must not take any further step affected by the concern, receive, transfer or return relevant funds, or communicate with the client or another party about the concern unless authorised by the MLRO.
The MLRO will provide guidance regarding any restrictions on the matter and any further action required.