Hello there,

For purposes of the CIP, the bank is not required to search the trust, escrow, or similar accounts to verify the identities of beneficiaries, but instead is only required to verify the identity of the named accountholder (the trust). In the case of a trust account, the customer is the trust whether or not the bank is the trustee for the trust. However, the CIP rule also provides that, based on the bank’s risk assessment of a new account opened by a customer that is not an individual, the bank may need “to obtain information about” individuals with authority or control over such an account, including signatories, in order to verify the customer’s identity.200 For example, in certain circumstances involving revocable trusts, the bank may need to gather information about the settlor, grantor, trustee, or other persons with the authority to direct the trustee, and who thus have authority or control over the account, in order to establish the true identity of the customer.

The named accountholder (The Trust), refers literally to the exact name of the trust, or just to the individual name? (E.g. John Smith Family Trust or John Smith)

I mean, for CIP and purposes, should I verify documentation on John Smith Family Trust itself or am I required to verify the identity of John Smith?

Should I verify just John Smith on the OFAC’s list or do I have to verify John Smith Family Trust also?

Thank You!

For purposes of the CIP, the bank is not required to search the trust, escrow, or similar accounts to verify the identities of beneficiaries, but instead is only required to verify the identity of the named accountholder (the trust). In the case of a trust account, the customer is the trust whether or not the bank is the trustee for the trust. However, the CIP rule also provides that, based on the bank’s risk assessment of a new account opened by a customer that is not an individual, the bank may need “to obtain information about” individuals with authority or control over such an account, including signatories, in order to verify the customer’s identity. For example, in certain circumstances involving revocable trusts, the bank may need to gather information about the settlor, grantor, trustee, or other persons with the authority to direct the trustee, and who thus have authority or control over the account, in order to establish the true identity of the customer.

For CIP and OFAC purposes, should I obtain identifying information only for John Smith Family Trust, or am I required to obtain the identity of John Smith as well.


Thank You!