Definition of Customer

Is a branch of a foreign government considered to be a customer for CIP purposes? We have an attorney's office that wants to open an account on behalf of a foreign government. I'm trying to determine the documentation I need for this account. I've re-read the final regs and have just managed to confuse myself.

I think it does meet the definition of a customer. However only the person opening the account needs to give you the 4 required pieces of info on themselves( the individual-ss#, dob, address, and name) along with the id verification piece. This should meet the requirement.