The rule talks about identification and about verification. What’s the difference?
Identification refers to the basic information you must get about your client to know who they are whenever you are retained to provide legal services.
Verification refers to the information you must obtain to confirm that your client is who or what they say they are. Verification is required only when you are acting for a client or giving instructions on behalf of a client regarding the receiving, payment or transferring of funds, i.e. a “financial transaction”.