When a trust holding company applies for a Binance account, the core of the beneficiary structure declaration is not the identity of the "trust company" itself, but rather looking through the trust arrangement to identify the natural persons who ultimately own or control the account. Binance's institutional verification rules explicitly include indirect ownership through "trust structures and other means" within the scope of UBO identification. For a trust holding company, what you need to declare is usually not just the shareholders at the company level, but also the settlor, trustee, beneficiaries of the trust, and any natural person who exercises ultimate effective control over the trust or the company.
The world's largest cryptocurrency exchange by trading volume,leading in security and liquidity.
New user benefit: Enjoy 20% off trading fees upon registration!
First, clarify: What Binance actually requires in institutional verification
In Binance's legal entity verification framework, the concepts directly related to the beneficiary structure are Related Parties and Ultimate Beneficial Owners (UBOs). Related parties include UBOs, directors, senior officers, controllers, and authorized traders. Binance requires the identification of all UBOs who own at least 25% of the ownership, and in some cases the threshold may be lowered to 10%.
The key definition here is: an Intermediary Beneficial Owner (IBO) is a non-natural person entity that can "directly or indirectly (including through trust structures and other means)" own or control a certain percentage of interest in a legal entity; while a UBO is the natural person who ultimately owns or controls those interests. In other words, if there is a trust above your trust holding company, the trust itself is an IBO, but what Binance ultimately requires is the natural person (or persons) behind that trust.
Binance also states that for complex ownership structures, the customer service team will provide guidance on document preparation based on the specific situation; if a complete shareholder list cannot be provided due to the organization type, the limitation must be clearly stated, and Binance will offer alternative solutions. This means that while a trust structure is more complex than an ordinary company, it is not impossible to apply. The key lies in truthfully disclosing the structure and cooperating with the look-through process.
Three layers of roles that a trust holding company needs to declare
Layer 1: Related parties at the company level
Regardless of the shareholder structure, the following roles usually need to be declared:
- Directors/Senior Officers: Persons responsible for the daily management and key decisions of the company.
- Controllers: Persons who can exert significant or effective influence over the company's activities, whether or not they hold a formal management title or ownership. If the trustee or protector of the trust is actually directing the company's decisions, this person may also fall into the controller category.
- Authorized Traders: Persons authorized to conduct trading operations on behalf of the company.
Layer 2: Key natural persons in the trust arrangement
Binance's official FAQ does not separately list declaration fields for trusts, but the FATF's transparency requirements for legal arrangements (including trusts) provide a reference framework: the beneficial ownership information to be obtained covers settlors, trustees, protectors (if any), beneficiaries (or classes of beneficiaries), and any other natural persons exercising ultimate effective control over the arrangement. While this is an international standard rather than a direct Binance rule, Binance, as an AML/CTF-regulated institution, follows the same look-through logic as this framework.
Specifically for your declaration:
- Settlor: The person who places assets into the trust. If the settlor is a natural person, they usually need to be declared as a UBO or related party. If the settlor is another entity, you need to continue looking through to the natural persons behind it.
- Trustee: The trust company itself or a natural person trustee. If the trustee is a licensed trust company (legal entity), it exists in the structure chain as an IBO, but Binance ultimately needs to know who within the trustee entity actually controls this trust — this may be a director of the trustee company or a trust manager.
- Beneficiaries: If the trust deed specifies specific beneficiaries (natural persons), and those beneficiaries hold an interest in the trust that meets or exceeds Binance's applicable ownership threshold (25% or 10%), they need to be declared as UBOs. If the beneficiaries are a class of persons rather than specific individuals (for example, "the settlor's children"), Binance may require an explanation of the class and decide based on risk whether specific individuals need to be identified.
- Protector: If the trust has a protector and that protector has the power to remove the trustee or veto decisions, this person may constitute a controller and needs to be declared.
Layer 3: UBOs after look-through
If the trust holding company itself holds a Binance account, and the beneficiary of the trust is another company, the look-through cannot stop at the company level. Binance's IBO/UBO distinction is designed precisely for this: trace upward layer by layer until you find the natural persons who ultimately own or control the interests. You need to prepare an ownership structure chart, starting from the trust holding company applying for the account, marking each entity's name, place of registration, and shareholding percentage layer by layer, until every branch ends with a natural person.
Common sticking points in practice
The trust deed does not list specific beneficiaries. Some trusts (especially discretionary trusts) give the trustee discretionary power, and the beneficiaries are a class rather than fixed individuals. Binance's FAQ allows you to explain limitations and negotiate alternative solutions when complete information cannot be provided. You need to prepare an explanation of the beneficiary class and distribution mechanism clauses in the trust deed, and be ready to explain why specific individuals cannot be locked in at the application stage. The review outcome depends on Binance's compliance team's judgment of the trust's risk profile; there is no uniform answer.
The trustee is a company rather than an individual. If the trustee is a trust company, you need to mark this company in the structure chart, then continue looking through to the natural persons who control the trust company (usually its directors or ultimate shareholders). At the same time, the person who actually operates the trust account (such as a trust manager), if authorized to trade on Binance on behalf of the trust holding company, may need to be declared separately as an authorized trader.
Multiple beneficiaries collectively exceed the threshold but individually do not. Binance's ownership threshold is calculated based on each individual UBO's holding percentage. If three beneficiaries each hold 20%, none individually reaches 25%, but in some cases Binance may still require identification of all beneficiaries (if the 10% threshold applies or the risk is higher). Do not make your own judgment that "collectively exceeding is sufficient" — follow the actual requirements of Binance's review team.
Document preparation: Structure chart and trust documents are core
Documents Binance may require include the company shareholder register, corporate structure chart, official company documents showing ownership percentages, and proof of identity and address for natural persons. For a trust holding company, it is recommended to additionally prepare:
- Pages from the trust deed concerning beneficiaries, trustee powers, and protector clauses (necessary redaction of sensitive information is acceptable, but retain clauses relevant to beneficial ownership determination).
- An ownership structure chart, drawn upward from the trust holding company to natural persons, with each entity marked with its shareholding percentage and each natural person marked with their role in the trust.
- If the trustee is a company, the registration documents and director list of that trustee company.
The submission entry is in the related parties information section of Binance's institutional account verification process. After submission, check the review result on the verification status page. If additional materials are requested, provide them according to the specific items listed in the ticket or email; do not stop by guessing on your own that "it should be enough."
A reality you need to accept in advance
There is no standardized approval template for institutional verification of trust structures. Binance's FAQ explicitly states that complex structures are handled on a case-by-case basis. This means the review time may be longer than for ordinary corporate accounts, and multiple rounds of supplementary document requests may occur. If you are unable or unwilling to disclose the natural person information behind the trust, the Binance account application will likely not be completed — this is not an additional restriction targeting trusts, but a fundamental requirement for all institutional accounts under the AML/CTF framework.
The world's largest cryptocurrency exchange by trading volume,leading in security and liquidity.
New user benefit: Enjoy 20% off trading fees upon registration!
