Answer:
The regulatory requirement is that you first determine who your customer is. In the case of a true trust, the trust itself is your customer and you are required to complete your CIP procedures on the trust. Many banks also apply their CIP procedures, as a matter of policy, to the trustee(s). Whether or not your bank applies those procedures to beneficiaries of a trust will also be a matter of policy. While I can't cite hard numbers, it's reasonable to assume that a smaller number of banks do so.
First published on BankersOnline.com 10/15/07