The Money Laundering Regulations require Keystone to identify and assess the risks of money laundering, terrorist financing and proliferation financing. The Firm's wider anti-financial crime framework also considers sanctions, fraud, bribery and corruption, tax evasion and other risks relevant to its business.
The Firm's assessment of those risks is recorded in its Practice-Wide Risk Assessment ("PWRA"). The PWRA considers factors such as:
The PWRA is a Firm-level assessment. It is designed to identify the risks facing Keystone as a business and the controls we use to mitigate those risks. It does not determine the risk of any individual client or matter.
When assessing a client or matter, you must apply your own professional judgement and consider the specific circumstances of the instruction. A matter may present elevated risk even where the client is longstanding or otherwise familiar to you.
The purpose of the Client and Matter Risk Assessment is to determine whether the level of due diligence, ongoing monitoring and internal oversight should be adjusted to reflect the risks presented by that particular instruction.
You should therefore read the PWRA as part of your compliance induction and remain familiar with its conclusions. In particular, you should be alert to matter characteristics that fall outside Keystone's normal client, sector, geographic or transactional profile.
Where a client, matter, transaction structure, source of funds or jurisdiction presents unusual or elevated risk, this must be reflected in your Client and Matter Risk Assessment and escalated in accordance with the Firm's procedures.