An individual or entity that holds or manages assets on behalf of others, either as a trustee responsible for administering trust assets or as a custodian focused on safekeeping and record-keeping. This role typically involves fiduciary or legal responsibilities to protect and maintain the assets in accordance with relevant laws.
Main/
Trustee/Custodian
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Code
AT0020
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Name
Trustee/Custodian
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Version
1.0
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Category
Professional Services & Advisors
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Created
2025-01-22
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Modified
2025-04-02
Related Techniques
Trustees or custodians of self-managed or private pension funds may be complicit or exploited if they:
- Facilitate large contributions without adequate source-of-funds validation.
- Overlook suspicious or inconsistent beneficiary designations, enabling covert criminal beneficiaries.
- Permit frequent rollover requests that obscure the path of illicit funds, frustrating financial institutions' ability to monitor transactions effectively.
Escrow agents function as a neutral party holding funds during real estate closings, acting in a trustee or custodian capacity. Criminals exploit this role by:
- Depositing illicit funds into the escrow account under the guise of standard buyer payments.
- Leveraging the third-party oversight image to reduce scrutiny, then disbursing proceeds after a rapid resale as though they stem from a legitimate transaction.