The responsible lawyer's role

While aspects of the CDD process are supported administratively by the Clients Team, responsibility for understanding the client and assessing the adequacy of the information obtained remains with the responsible lawyer.

Before accepting instructions, the responsible lawyer should be satisfied that:

• they understand who the client is;
• they understand who owns or controls the client;
• they understand why the client has approached Keystone;
• the proposed instructions are credible and make commercial and legal sense; and
• no information obtained gives rise to unexplained concerns.

Where information is incomplete, inconsistent or unusual, additional enquiries should be made before proceeding.