Sanctions Evasion Reference

Omnibus account

A single account in which a custodian or broker holds securities for many underlying clients together, in its own name, rather than in a separate named account for each.

also known as

nominee account, street name account

reviewed

2026-09-23

Cite this page
APA 7 
Sanctions Evasion Reference. (2026, September 23). Omnibus account. https://sanctionsevasion.org/reference/glossary/omnibus-account/
Chicago 
Sanctions Evasion Reference. “Omnibus account.” Last reviewed September 23, 2026. https://sanctionsevasion.org/reference/glossary/omnibus-account/.
BibTeX 
@misc{ser-reference-glossary-omnibus-account,
  author = {{Sanctions Evasion Reference}},
  title  = {Omnibus account},
  year   = {2026},
  note   = {Last reviewed 2026-09-23},
  url    = {https://sanctionsevasion.org/reference/glossary/omnibus-account/}
}

The date is when this page was last reviewed, not when it was first published.

An omnibus account pools many clients’ holdings of the same security into one account at a custodian, broker or central securities depository, recorded in the intermediary’s name rather than the underlying owner’s. It is an ordinary feature of modern securities markets: it is what makes large-scale clearing and settlement efficient, and most omnibus accounts have nothing to do with evasion.

What it does to visibility is the relevant point here. A US custodian holding an omnibus account for a foreign intermediary generally sees the intermediary, not the intermediary’s own clients. If one of those clients is a sanctioned party, the custodian has no direct way to know it unless the intermediary tells it, screens on its behalf, or the intermediary itself is listed.

That is a narrower version of the problem nested correspondent accounts create in banking: an intermediary standing between the institution that can see a name and the institution that can block a payment.

Where this term is used

Related terms

  • Correspondent banking — An arrangement in which one bank holds an account for another and provides payment and other services on its behalf, usually to give it access to a foreign currency.
  • Beneficial owner — The natural person who ultimately owns or controls an entity, or on whose behalf a transaction is conducted, regardless of whose name appears on the register.
  • Nominee director — A person who is formally appointed to a company board but who acts on the instructions of an undisclosed party rather than exercising independent judgement.
  • Nested account — The use of a bank's correspondent account by that bank's own respondent institutions, giving unnamed third banks indirect access to the correspondent.

Sources

  1. ISSA Financial Crime Compliance Principles for Securities Custody and Settlement: Background & Overview. International Securities Services Association (ISSA), 2019. Section 4.6, Omnibus Accounts; Section 4.7, Disclosure of Holdings.
  2. Enforcement action: Clearstream Banking, S.A.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2014. Penalty notice, 2014-01-23, US$151,902,000.

All glossary terms