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Do I have an obligation to ask my client if they are acting for a third party?

While not required, it would be prudent practice to ask the client if a third party is involved. If the client is acting for or representing a third party, the rule requires you to obtain the identification information about the third party. If there is a financial transaction, you must verify the identity of both the client (including the individual instructing you on the client’s behalf if the client is an organization) and the third party. Accordingly, you should take reasonable measures to determine if a third party is involved if there is a financial transaction.