Controlling Persons. Equity Interest holders in the case of a trust that is a SGFI In the case of a trust that is a SGFI, which are the parties that are regarded as the holders of the Equity Interests (financial accounts of the trust)? In the case of a trust that is a SGFI, an Equity Interest is considered to be held by any person treated as a settlor or beneficiary of all or a portion of the trust, or any other natural person exercising ultimate effective control over the trust. This means that where the settlor, beneficiary or other person exercising ultimate effective control over the trust is itself an Entity, the SGFI would be required to look through that Entity to determine the relevant Controlling Person(s) who will be considered to be the Equity Interest Holder. In the conduct of the look through requirement, SGFIs may rely on information collected and maintained pursuant to AML/KYC Procedures. In respect of New Accounts, SGFIs must obtain a self- certification, which may be part of the account opening documentation and confirm the reasonableness of such self- certification based on the information obtained by the SGFI in connection with the opening of the account, including any documentation collected pursuant to AML/KYC Procedures. The AML/KYC Procedures applied by the SGFI must be consistent with MAS’ AML/CFT requirements, which are in turn consistent with the FATF Recommendations (as adopted in February 2012). Added on: 28 August 2020 E)
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Sources: Faqs on the Common Reporting Standard, Faqs on the Common Reporting Standard, Faqs on the Common Reporting Standard