Start with the capacity in which each entity acts
Write the company name and identifier, the trust name and the company's trustee capacity. Record the designated service and identify the customer under that service. Draw separate links for shares, directorship, trustee appointment, appointment or removal powers and authority to instruct the practice. A company search helps with company facts; it does not describe every power in the trust deed. Avoid treating an ABN and an ACN as interchangeable identifiers.
Trace people using the applicable customer-type rules
Read AUSTRAC's body-corporate guidance alongside its trust guidance. Ownership percentages and other means of control can both matter, and exceptions depend on the customer and conditions. A diagram is an organising tool rather than a substitute for those tests. For every relevant link, record the supporting document, its date and the conclusion. Explain any stopping point under an applicable exception so the next reviewer can reproduce the reasoning.
Test a change in trustee or controller
Suppose the same company remains trustee but its directors change, while a separate person retains a power to replace it. Updating the director list alone may leave the control picture incomplete. Check which roles changed, which powers continued and whether the representative still has authority. Reconsider risk and verification needs under the program. Do not infer suspicious conduct from a structural change without examining the surrounding facts.
Make the map useful during a handover
Use a legend that distinguishes ownership, control and representation. Identify unresolved links explicitly and keep the underlying deed and registry evidence accessible to authorised reviewers. Date the map and record the event that would make it stale, such as a trustee replacement, share transfer or amended appointment power. A concise explanation beside the diagram is often more useful than a complicated graphic containing no evidence references or decision owner.
Official sources
Use these primary sources to confirm the current rules and apply them to your circumstances.
Sources checked .
Frequently asked questions
Are all company directors automatically the trust's only beneficial owners?
No. Assess the relevant ownership and control rules and the actual trust powers. Directorship alone does not exhaust the analysis.
Is a structure diagram legally required in every file?
This guide recommends a practical recording method. The duty is to establish and retain the required matters; the appropriate format depends on the file.
Should an old map be deleted after a restructure?
Keep the necessary historical record and label the new map clearly. The change history can explain earlier decisions and later review triggers.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser. See our editorial and correction standards.