A trust account was opened at our bank and it names twenty or more people. For CIP purpose we are doing CIP on those who are opening the account and can transact. Are we under any regulatory requirement to do CIP and OFAC checks on all named parties in the trust?

The trust is a legal entity and the CIP regulation says the trust is the customer. That's whose identity you must verify as far as the law is concerned.

Saying the trust "names" 20 or more people isn't precise enough to respond to. A trust names trustees. It also names beneficiaries. Some banks identify trustees because their CIP requires it. Banks are generaly not in a position to identify beneficiaries and make no attempt to do so.

OFAC is risk based...you decide whose names you will check against the OFAC list.

You have 20+ people that can transact on a trust account (20 or more trustees)?

The trust is your customer and banks I have worked with also perform due diligence (including CIP) on all trustees. Beneficiaries are screened to OFAC if they are receiving distributions.

No. I'm told that there are many individuals that the trust agreement names. However, there will be only two signers that control the account and these are the two they will do CIP on. Should they be doing more? Example: A Family Trust account controlled by two people, but the entire family is named within the trust document.

You must CIP the trust. Whether you apply the same CIP standard to the trustees is a matter of your CIP policy (we do).

We would CIP the trust (regulation adn policy) and the two signers (policy only), no one else.