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If I am not able to obtain information on the directors and beneficial owners, may I continue to act for the client?

If despite reasonable efforts you are unable to obtain the information, you must then take reasonable measures to ascertain the identity of the most senior managing officer of the organization and assess the organizational client’s activities in the context of any risks that the financial transaction(s) may be part of dishonest, fraudulent or illegal activity. If the organization’s structure is more opaque than transparent, this may be a warning that the organization could be engaged in or facilitating unlawful activities. You will need to assess risk accordingly and keep in mind circumstances that may trigger your duty to withdraw.