PRINCIPLES OF TRUST ONBOARDING

ON BOARDING A CLIENT DO WE KNOW WHO YOU ARE?

KNOW YOUR CLIENT Identification and Address Verification Due diligence checks and Google searches How much is expected? What is the level of activity for this account? Source of Wealth (SOW), and Net Worth?

DOCUMENTING FOR KYC Certified Copy Passport or other Government ID with a picture, date of birth and signature Utility bill usually not older than 3 months (varies from company to company) For a legal entity, formation documents e.g. Memorandum and Articles of Incorporation, Certificate of Incorporation, Registers of Members/Shareholders, Directors and Officers, Certificate of Incumbency, Certificate of Good Standing (or equivalent documents) World Checks Google Searches Other as required

“COMPLEX STRUCTURES” VETTING AND DOCUMENTING FROM ENTITIES TO INDIVIDUALS If you’re dealing with corporate or other legal entities and other corporate or legal entities are holding the shares (sometimes as nominees), you have to continue to drill down until you arrive at the individual(s) who is the beneficial owner. Exceptions are companies/legal entities that are listed on the Stock Exchange.

“COMPLEX STRUCTURES” VETTING AND DOCUMENTING LEGAL/TAX OPINIONS Particularly important for connections with tax sensitive jurisdictions such as the US, Canada, Mexico, the UK and other parts of Europe. The opinion should indicate any tax reporting or other requirements of the Trustee, the appropriateness of the structuring for this particular client, factors to consider in making distributions and how these impact the different levels of beneficiaries (Settlor and family members/others), etc.

COMMUNICATION & DISCLOSURE OF INFORMATION AUTHORIZATION – Know the individuals with whom you are authorized to communicate and ensure KYC documentation received for each AGREEMENTS – COMMUNICATION AND ELECTRONICS – Important indemnification of your company SIGNATURE CARDS – To be signed by individuals with whom you are authorized to communicate; For corporations obtain an authorized signatory list.

DOCUMENT REVIEW COMPLETE – Application forms to be fully completed and properly executed. Blank spaces should be filled in with “n/a” if not applicable TRANSLATIONS – Documents not in English should be accompanied with certified translations APPROPRIATELY STRUCTURED – Variations to this but as an example, Special Entities or other operating companies should not be held directly by the Trust. Trust assets should be held by an underlying company ESSENTIAL DOCUMENTS: CRS & FATCA SELF CERTS; W8BEN/ W8BEN-E/W9. These are mandatory documents to be completed by all beneficial owners, economic contributors (see also Controlling Persons re. CRS)

BEST PRACTICES OF TRUST ADMINISTRATION KNOW THE TRUST DEED – It’s your most important document as it defines the parameters within which you will oprate TRUST TYPE: DISCRETIONARY, NON-DISCRETIONARY, RESERVED POWERS, FIXED INTEREST, REVOCABLE, IRREVOCABLE, CUSTOMIZED – The type of trust determines the role of the Trustee and other parties, e.g the Settlor, Investment Advisor, Protector, Tax Considerations etc. INVESTMENT PARAMETERS – What is your role or the role of others? LETTER OF WISHES – Become acquainted with the wishes of the Settlor during and after his lifetime. Review every few years and prompt the Settlor to review in the event there is a need to make changes. Remember that this is not a document that is binding on the Trustees. SEGREGATION OF CAPITAL AND INCOME – Determine if there is a need for this and adhere to requirements REQUIREMENTS FOR TAX/LEGISLATIVE/REGULATORY COMPLIANCE – Know what needs to be done and when. Financial Statements should be prepared for these structures (ideally for all structures). Check to see if Audited accounts are needed

BEST PRACTICES OF TRUST ADMINISTRATION P.2 PRIMARY BENEFICIARIES – Who are your Primary Beneficiaries CONTINGENT BENEFICIARIES – What are distributions to these persons contingent upon? RESIDUAL BENEFICIARIES – Who receives what is left after all specific gifts are distributed and all debts, obligations administrative expenses have been settled? DOCUMENT CONVERSATIONS WITH FOLLOW UP EMAILS/CONDUCT CALL BACKS – You’ve received information by telephone. Follow up and document by recording the salient points in an email to the individual. There acknowledgement by return email is confirms the exchange. TRUSTEE MINUTE – Decisions and exercise of discretion should be minuted. It also protects the individual Administrator as it evidences a corporate and not an individual decision.

BEST PRACTICES OF TRUST ADMINISTRATION P.3 ACCOUNTS/FINANCIAL STATEMENTS – Ideal for all Trusts. Could be very useful if the Trust is ever challenged STORE ORIGINAL DEEDS OR CONTRACTUAL DOCUMENTS IN SAFE KEEPING – If there is a fire or other catastrophic event these essential and important documents are protected. They are also not easily accessed without the proper permissions and can be tracked. This is not an exhaustive list. Stop and think of some of your own 