Likely. I remember a case once where I had a US client ring us up and he knew the account number, all account details, every transaction but he wasn't listed on the account name or as a signatory. It was some trust or done via an accountant, I can't remember exactly but the story he told us was that it was his metal but he did it through this trust/accountant, problem was that the accountant was in jail for murder and couldn't issue any instructions to us to liquidate the metal. He was obviously set it up trying to avoid the US govt knowing he had metals. Unfortunately we had to say no luck as while we thought his story was correct, we couldn't risk acting on his instructions and not the authorised signatory in our records.