CMFAS RES5 AML / CFT question: establish relations before verification

As a general rule a financial adviser completes verification of a customer's identity before establishing business relations. It may establish relations before verification is complete only where:

• A the customer signs a written waiver and undertakes to provide the verification documents within 12 months
• B deferral is essential to avoid interrupting business, ML/TF risks are effectively managed, and verification is done as soon as reasonably practicable
• C the customer is an individual paying in cash, the amount is below the firm's internal limit, and a manager approves
• D verification is postponed until the first claim or withdrawal, provided the customer has been screened against the MAS lists