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#2256820 - 07/16/21 06:43 PM BENEFICIAL OWNERSHIP INVOLVING TRUSTS
Susan, BSA Officer Offline
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We are opening an account where it has 2 trusts and an individual as beneficial owners. Do I need to CIP the trustees of the trusts? Thank you for any input. I have gotten different answers. Thanks!

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#2256825 - 07/16/21 07:13 PM Re: BENEFICIAL OWNERSHIP INVOLVING TRUSTS Susan, BSA Officer
edAudit Offline
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#2256826 - 07/16/21 07:15 PM Re: BENEFICIAL OWNERSHIP INVOLVING TRUSTS Susan, BSA Officer
edAudit Offline
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a less official version

Trusts
Trusts are not included in the definition of legal entity customer, other than statutory trusts
created by a filing with a Secretary of State or similar office.1

https://www.ffiec.gov/press/pdf/Ben...l%20Entity%20CustomersOverview-FINAL.pdf
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#2256866 - 07/19/21 03:26 PM Re: BENEFICIAL OWNERSHIP INVOLVING TRUSTS Susan, BSA Officer
ColoradoAML Offline
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My understanding of the question is that a legal entity customer opened ac account, and two beneficial owners of the legal entity are trusts. If that's the case, then yes, you must identify and verify the identity of the trustees of the trusts. See Question 20: https://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf

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#2256898 - 07/19/21 06:28 PM Re: BENEFICIAL OWNERSHIP INVOLVING TRUSTS Susan, BSA Officer
John Burnett Offline
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You only need to identify and verify the identity of a single trustee for each trust.
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#2256978 - 07/20/21 08:07 PM Re: BENEFICIAL OWNERSHIP INVOLVING TRUSTS Susan, BSA Officer
Susan, BSA Officer Offline
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Thanks everyone!

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