It's been a while since I looked into this. When a trust owns a LEC the Trustee is the Control Person. When the trust is opening the account, excluding statutory trusts, the trust is not considered a LEC so, unless the Bank's CIP or other policy requires it, the CDD Rule itself would not be applicable to the trust.
Does anyone disagree? If so, I'd be interested in thoughts as to why the above is incorrect.
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu