Trust Account

• Complicit professionals, such as lawyers and accountants, establish trust accounts under their control or on behalf of clients, holding illicit proceeds without revealing the criminal’s identity.
• The legal structure of a trust and professional privilege obscure the true beneficiary, making it more challenging for authorities to link funds to the criminal.
• This intermediary arrangement provides distance between illicit assets and their actual owner.

• Escrow arrangements in real estate typically function as a form of trust account controlled by a neutral third party.
• Criminals deposit illicit funds into the escrow/trust account during a property purchase, masking the true source by presenting the transaction as a legitimate buyer deposit.
• The trust account’s third-party oversight and legitimate appearance reduce scrutiny, allowing a quick sale flip that reintroduces the funds as proceeds from a documented real estate transaction.

• Criminals use falsified passports or proof-of-address documents to create trust arrangements or be listed as trustees/beneficiaries.
• With these accounts established under forged identities, they can hold or transfer funds in the name of the trust, concealing their direct involvement.
• The fake credentials obscure true beneficial ownership, making it difficult for investigators to trace the sources and controllers of deposited assets.

• Criminals deposit illicit funds into attorneys' or accountants' trust accounts (e.g., IOLTA), leveraging confidentiality obligations to hide the true source of the money.
• By invoking perceived professional secrecy, they frustrate financial institutions' and law enforcement's attempts to scrutinize beneficial owners or the reasons behind each deposit.
• Multiple client transactions are commingled, making it more difficult to trace individual ultimate beneficiaries.

• Through corrupt or coerced legal rulings, criminals direct purportedly legitimate settlement funds into trust accounts overseen by complicit or negligent trustees.
• This legal structure shields the true beneficiary and complicates investigations, as the trust arrangement conveys a superficial legitimacy and severs direct links to the funds' criminal origins.

• Lawyers, accountants, and corporate service providers often maintain client trust accounts under their own name or firm, enabling criminals to deposit illicit proceeds.
• Confidentiality obligations and attorney-client privilege can conceal the ultimate source and beneficiary, preventing direct linkage to the criminal.
• Funds move rapidly in and out of these accounts with limited documentation, adding layers to obscure beneficial ownership.

• Criminals leverage trust accounts administered by nominee or non-professional trustees to layer and obscure beneficial ownership.
• They funnel funds through these accounts, repeatedly changing signatories or beneficiaries so the true controller is never transparently recorded.
• The account’s inherent legal protections and confidentiality features hinder financial institutions’ attempts to trace ultimate beneficial ownership.

• Criminals open trust accounts in the trust’s name to receive large deposits of illicit proceeds, concealing the true beneficial owner.
• They utilize professional intermediaries to establish multiple sub-accounts across jurisdictions, enabling frequent fund transfers that fragment the paper trail.
• The built-in opacity of trust structures impedes effective AML measures, making it difficult to link deposits to their illicit origin.

Offenders place assets and funds into trust accounts under nominal trustees or through complex structures that distance the true owner from the assets. By layering or renaming beneficiaries across jurisdictions, they conceal taxable income or capital gains. This setup complicates due diligence on beneficial owners and asset flows, making it more difficult for tax authorities to detect undeclared earnings.