The level of client due diligence required depends on the nature of the client, the matter, and the financial crime risks identified through the Client and Matter Risk Assessment.
Certain categories of client may often present lower levels of inherent risk because they are subject to substantial public disclosure, regulatory oversight, or equivalent anti-financial crime requirements. Depending on the circumstances, these may include:
Conversely, certain clients, structures, sectors, or jurisdictions may present elevated risk or require greater scrutiny because ownership, control, source of funds, source of wealth, or other relevant factors are less transparent. Examples may include:
These categories are indicators only and do not determine the level of risk by themselves. A publicly listed or regulated entity may still present heightened risk in a particular matter, while an overseas corporate entity or private structure may present comparatively limited risk once its ownership, control, purpose, and funding are properly understood.
The Firm's Client Due Diligence Checklists and Client and Matter Risk Assessment framework reflect these differing risk profiles and prescribe the verification measures ordinarily required. Lawyers must follow the relevant checklist but must not assume that reduced verification requirements mean that a client or matter is necessarily low risk.
The responsible lawyer must consider whether the due diligence undertaken is sufficient to understand and mitigate the risks presented by the client and instruction. Where the overall circumstances indicate elevated financial crime risk, additional enquiries, enhanced due diligence, or escalation may be required regardless of client type or the standard verification requirements applicable to that category of client.