are a key component of Keystone's anti-financial crime framework. Unlike money laundering, sanctions do not depend on whether funds or assets derive from criminal conduct. A transaction may be entirely legitimate in origin yet still be prohibited because of the parties involved, the destination of funds, the goods or services concerned, or the jurisdiction connected with the matter.
You must therefore treat sanctions as a distinct area of risk and must not assume that the absence of money laundering concerns means an instruction is capable of proceeding.
The Firm's detailed requirements are contained within the AMLAS Policy and supporting sanctions procedures.
Keystone may decline or restrict an instruction even where the proposed work is not clearly prohibited by law. This may occur where the ownership, control, jurisdictional, funding, trade, insurance or reputational risks cannot be understood or mitigated to the Firm's satisfaction, or where the work would be inconsistent with the Firm's risk appetite as set out in the AMLAS Policy and PWRA.