What is a nominee or third-party account?¶
A nominee or third-party account is held in one name while handling value connected with someone else. The arrangement may be legitimate, abusive or imposed without informed knowledge.
Holder, controller and beneficial owner may separate¶
Trustees, agents, professionals, carers and businesses can lawfully manage funds. Offenders can use associates, mules or compromised victims to conceal receipt. The holder may be involved, deceived, pressured or unaware.
Establish the practical arrangement¶
Identify who opened the account, supplied funds, gave instructions, accessed it and benefited. Preserve mandates, source-of-funds records, communications, devices, logins, onward transfers and cash withdrawals.
Repeated links to another person, shared contacts or activity outside the holder's circumstances may support common control but need comparison with legitimate family or business explanations. Report legal holder and practical controller separately.
The point to remember
Determine who supplied, controlled and benefited from third-party funds instead of treating the account-holder name as proof of ownership.