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Tax Evasion

Offshore Trust Layering via Professional Enablers

Wealthy individuals use networks of professional enablers including lawyers, accountants and trust administrators to establish multi-jurisdictional trust and corporate structures that conceal beneficial ownership of income-generating assets, disguise the true origin of wealth, and facilitate the evasion of tax obligations. Funds move through nominee trustees, opaque holding vehicles and secrecy-jurisdiction accounts before distribution to the ultimate beneficiary.

Firm typesBank / Credit InstitutionWealth ManagerPayment Institution (PI)E-Money Institution (EMI)
ProductsCross-Border PaymentsFX TransfersE-Money Accounts
CustomersHigh Net Worth IndividualsCorporatesAgents & Intermediaries
Key terms:

What it is

Wealthy individuals use networks of professional enablers including lawyers, accountants and trust administrators to establish multi-jurisdictional trust and corporate structures that conceal beneficial ownership of income-generating assets, disguise the true origin of wealth, and facilitate the evasion of tax obligations. Funds move through nominee trustees, opaque holding vehicles and secrecy-jurisdiction accounts before distribution to the ultimate beneficiary.

Control objective

Detect multi-jurisdictional trust and corporate structures established by professional enablers to conceal beneficial ownership and facilitate tax evasion by high-net-worth individuals.

Data required

  • Full beneficial ownership chain including settlors, trustees, protectors and beneficiaries
  • Jurisdiction of trust and each underlying entity, and whether any are on non-cooperative or secrecy lists
  • Identity and professional registration of all intermediaries acting as nominees or trustees
  • Source of wealth documentation for trust contributions and asset transfers
  • Nature, valuation and income-generating capacity of underlying assets held in trust
  • Distribution history and beneficiary relationship to the settlor
  • Tax-residency declarations and automatic exchange of information (AEOI/CRS) status
  • Links to jurisdictions with limited tax-information-exchange agreements