US: Corporate trustees can be company beneficial owners

Law firms are issuing analysis of the customer due diligence rules now enforced on American banks by the US Treasury’s Financial Crimes Enforcement Network (FinCEN), mandating the identification and verification of beneficial owners of legal entity customers. One point is that the trustee of a trust that directly or indirectly owns 25 per cent or more of the equity interests of a legal entity customer is one of its beneficial owners, whether the trustee is a natural person or a legal entity.