If your client is acting for or representing a third party (e.g. an attorney acting under a power of attorney), you must identify both your client and the third party. The third party may or may not be directly instructing your client, for example as a principal instructs an agent. If the third party is instructing your client in relation to a financial transaction, you must verify the identity of both the client and the third party. When your client is acting for someone else you must obtain the same information for that other person as you would if they were your client: their full name, home address and telephone number, their occupation, and where applicable their workplace or business address and telephone number.

The same requirement applies if the third party is an organization such as a company: you have to get all of the information you would get if you were representing the organization directly.