(7) Specific Identification Issues
A. Trust, Nominee and Fiduciary Accounts
These type of accounts are easy to use to conceal sources of funds; therefore, it is necessary to verify the documents used in setting up the trust, fiduciaries, funds owners, ultimate beneficial owners and individuals authorized to remove trustees. Whenever there is a change of director, KYC must be completed for the new director.
There must be verification of the source of funds, reason for the funds transfers, if it is a regular, normal transfer than has been verified earlier, than it is considered as normal and legitimate transaction.