A. Customer due diligence and tipping-off

1. If, during the establishment or course of the customer relationship, or when conducting occasional transactions, a financial institution suspects that transactions relate to money laundering or terrorist financing, then the institution should:

(a) normally seek to identify and verify the identity [Reliable, independent source documents, data or information will hereafter be referred to as "identification data."] of the customer and the beneficial owner, whether permanent or occasional, and irrespective of any exemption or any designated threshold that might otherwise apply; and

(b) make a suspicious transaction report (STR) to the financial intelligence unit (FIU), in accordance with Recommendation 20.