The Client Identification and Verification Requirements, outlined in Rule 16, apply equally to all clients. Members must ensure that these requirements are fulfilled even if the client is a family member, a friend or well-known by the member.

The member does not need to go through the client identification and verification process for each matter with the same client unless the member believes that the information or the accuracy of it has changed. However, Rule 16 requires members to periodically monitor their business relationship with their client while they are retained.

Client identification and verification records must be accessible for audit purposes. Centralized digital storage of the client data is permissible.

Posted: 17 February 2026