When your client is an organization you should verify the client’s identity upon engaging in or giving instructions on their behalf to receive, pay or transfer funds, and must do so within 30 days. The 30-day window for verifying the identity of an organization does not apply to your obligation to verify the identity of the individual instructing you on behalf of the organization. You must verify the instructing individual’s identity at the time that you would verify the identity of any individual, i.e. when you engage in or give instructions in respect of the receiving, paying or transferring of funds.