Guidance on the term "customer"
4. The point at which a person becomes a customer will vary from business to business. However, the
DFSA considers that it would usually occur at or prior to the business relationship being formalised, for example, by the signing of a customer agreement or the acceptance of terms of business.
DFSA does not consider that a person would be a customer of a Relevant Person merely because such person receives marketing information from a Relevant Person or where a Relevant Person refers a person who is not a customer to a third party (including a Group member).
DFSA considers that a counterparty would generally be a "customer" for the purposes of this module and would therefore require a Relevant Person to undertake CDD on such a person. However, this would not include a counterparty in a transaction undertaken on a Regulated Exchange. Nor would it include suppliers of ordinary business services, for consumption by the Relevant Person such as cleaning, catering, stationery, IT or other similar services.
Representative Office should not have any customers in relation to its DIFC operations.