Although FinCEN provides some guidance regarding trusts, it is a complex issue. Reporting companies owned by multiple trusts or trusts with multiple individuals with varying degrees of control can raise particularly difficult issues for those responsible for CTA compliance.
It is advisable to keep abreast of any further guidance provided by FinCEN and may be advisable to obtain legal advice to determine the compliance obligations of the trust and the individuals who may be beneficial owners of a reporting company.