DPMS-BO-001High Risk

beneficial ownership

Red Flag

Trust or LLC wires funds for a precious metals purchase but the beneficial owners are concealed, and the trustee or manager is a professional nominee with no independent relationship to the metals.

Industry
Dealers in Precious Metals
Transaction Type
wire
Customer Type
legal entity
Category
beneficial ownership
Regulatory Source
Document:FIN-2014-G001 MSB Expectations
Type:FinCEN Guidance
CFR Citation:31 CFR §1010.230
SAR Category:Beneficial ownership
FinCEN Key Term:Nominee Trust Purchase
Last Verified:2026-04-15
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This red flag is provided for informational and educational purposes only. It is not legal, regulatory, or compliance advice. Always consult the official source document and a qualified compliance professional for guidance specific to your situation.

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