What is a nominee or third-party account?¶

A nominee or third-party account is an account held in one person or organisation’s name but used for funds connected with someone else.

Avoid this assumption: The named account holder is always the true owner, controller or beneficiary of the money.

There are legitimate arrangements. Solicitors, accountants, trustees, agents, carers and businesses may hold or manage funds for others.

There are also abusive arrangements. An offender may use an associate’s account to conceal ownership, receive criminal proceeds or distance themselves from transactions.

The account holder may be fully involved, partly aware, deceived, pressured or entirely unaware.

To assess the arrangement, identify who opened the account, who supplied the funds, who gave instructions, who accessed the account and who benefited.

Relevant evidence may include account mandates, payment instructions, communications, device access, login history, source-of-funds records, onward transfers and cash withdrawals.

Look for repeated transfers linked to another person, shared devices, common contact details or payments that do not fit the account holder’s known circumstances.

But do not treat unusual activity alone as proof of nomination or criminality. Legitimate family, business or professional arrangements can look similar.

A third-party account may also be a mule account, pass-through account or compromised victim account.

The legal holder and practical controller should be recorded separately.

Where funds are held on trust or for clients, specialist financial or legal support may be needed to interpret the structure.

When reporting, avoid saying that the named holder owned the funds unless the evidence supports that conclusion.

Operational takeaway¶

Investigate who supplied, controlled and benefited from funds in a third-party account rather than treating the account-holder name as proof of ownership.