Where the customer is a trust, the beneficial owners the financial adviser must identify include:
For a trust the FA must identify the settlors, the trustees, the protector (if any), the beneficiaries (including those within a designated class), and any natural person exercising ultimate ownership, control or effective control over the trust. It is not limited to the trustee or to current beneficiaries.
The BO of a trust spans settlor, trustee, protector, beneficiaries and any ultimate controller — not the trustee alone.
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