In which of the following scenarios should the customer be deemed to have an overly...

AML/CFT guidance from FATF emphasizes that overly complex ownership structures are a key red flag when they appear unnecessary for legitimate business purposes and may be designed to obscure beneficial ownership.

A privately held company owned by two individuals whose interests are held through multiple layers of trusts and foundations represents an unnecessarily complex structure. Trusts and foundations are frequently identified in AML typologies as vehicles that can be misused to conceal the true beneficial owners, especially when layered without clear commercial rationale. This complexity increases the risk of money laundering and necessitates enhanced due diligence.

By contrast, a trust with two co-trustees, including the grantor and a professional service provider, is common and not inherently complex. Similarly, family-owned businesses with many shareholders may be complex but are not automatically deemed “overly complex” if ownership is transparent. Multinational banks with layered ownership tied to a publicly traded holding company are also common and subject to regulatory oversight.

Therefore, the use of multiple trusts and foundations without clear justification is the clearest indicator of an overly complex ownership structure.