Your responsibilities

The Firm's central controls support, but do not replace, the responsible lawyer's understanding and professional judgement. For every new client and matter, the responsible lawyer must:

1. understand who the client is, who owns or controls them and who has authority to instruct;
2. understand the purpose and intended nature of the instruction and why it makes commercial and legal sense;
3. complete the Client and Matter Risk Assessment accurately and record any material risk factors or unusual features;
4. review the client due diligence completed and raise any gaps, inconsistencies or concerns;
5. understand and record the source of funds and, where required, the source of wealth;
6. obtain any required approval before work begins or funds are handled;
7. monitor the client and matter throughout the instruction and update the risk assessment when circumstances change;
8. stop and escalate anything that is inconsistent, unusual or not satisfactorily explained; and
9. make a formal internal report without delay where the applicable reporting threshold is met.

The Clients Team supports client onboarding, screening and central record keeping. It cannot determine whether the client's instructions, the proposed transaction or the movement of funds makes sense. Electronic checks and screening results are controls, not substitutes for the lawyer's knowledge of the client and matter.

Before proceeding, the responsible lawyer should be able to answer:

• Do I know who I am dealing with?
• Do I understand who owns, controls and benefits from the client or transaction?
• Do I understand what the client wants us to do and why?
• Do I understand where relevant money or assets have come from and where they are going?
• Is the information consistent across the due diligence, instructions, documents and payment arrangements?
• Can I explain and evidence why it is reasonable for Keystone to proceed?

If the answer to any of these questions is no, or if anything does not make sense, the lawyer must not proceed on assumption. They must make further enquiries or seek guidance from the Clients Team or MLRO, as appropriate.