Skip to content
BOL Conferences
Forums · Active Threads · Forum Rules · Mark All Read · Log In
BankersOnline.com Forums Banker Forums BSA/AML/CIP/OFAC Forum Beneficial Ownership & Trusts
Thread Options
#2269400 - 04/20/22 03:26 PM Beneficial Ownership & Trusts
Amy S Offline
100 Club
Joined: Sep 2020
Posts: 224
So..... (fake names) Electric LLC ......Bob & Sue Electric owned business 50/50. Bob died. Bob's 50% is now part of Bob's Trust, Sue is Trustee. How do I do the Beneficial Ownership on this one?

Return to Top
BSA/AML/CIP/OFAC Forum
#2269401 - 04/20/22 03:28 PM Re: Beneficial Ownership & Trusts Amy S
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Sue Electric - 50%
Sue Electric, Trustee - 50%
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2269404 - 04/20/22 04:03 PM Re: Beneficial Ownership & Trusts Amy S
Amy S Offline
100 Club
Joined: Sep 2020
Posts: 224
John, just to be clear, I do no list Bob's Trust as Beneficial Owner? I think I got it figured out. Thank you!
Last edited by Amy S; 04/20/22 04:47 PM.
Return to Top
#2269406 - 04/20/22 05:03 PM Re: Beneficial Ownership & Trusts Amy S
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,721
Illinois
A beneficial owner has to be a natural person. A trust does not have a heartbeat.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2269416 - 04/20/22 07:21 PM Re: Beneficial Ownership & Trusts BrianC
Amy S Offline
100 Club
Joined: Sep 2020
Posts: 224
Correct.

Return to Top
#2269434 - 04/20/22 09:34 PM Re: Beneficial Ownership & Trusts Amy S
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The citation for the applicable paragraph in the regulation is paragraph 230(d)(3) of 31 CFR 1010.230. If there is more than one trustee, pick one.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z