AML, Beneficial Ownership, and What StructureGram Does
Firms doing AML/CTF work ask where StructureGram fits. The short answer:
StructureGram maps beneficial ownership and control. It does not verify identity or screen anyone.
It is a structure intelligence tool, not an AML platform. It sits alongside your AML process and does one part of it well.
What StructureGram does
Makes beneficial ownership visible. Layered ownership, indirect holdings, control without equity, trust roles, interposed entities — the structural picture you need before you can decide who the beneficial owners are.
Models control as well as equity. Influence does not always follow shareholdings. Trustees, appointors, and directors are modelled explicitly, so control that never appears on a share register is still visible.
Keeps a point-in-time record. Structures change. StructureGram maintains a persistent record with versions, so you can show how a structure was understood at the time you assessed it — not just how it looks today.
Produces evidence of the work. A clear diagram and its underlying data demonstrate the reasonable steps you took to understand a client's structure.
What StructureGram does not do
Be direct with your compliance team about the boundary:
- No identity verification. StructureGram does not confirm that a person is who they say they are. No document checks, no biometrics, no electronic ID verification.
- No sanctions or watchlist screening.
- No PEP screening.
- No transaction monitoring.
- No compliance determinations. StructureGram does not decide who is a beneficial owner, whether a client is high risk, or whether an obligation has been met. It gives you the structure; the judgment stays yours.
StructureGram is not a substitute for AML software, and it does not on its own demonstrate AML compliance. It supports one part of the process — understanding the structure — and you will still need your own tools and procedures for the rest.
How firms actually use it
The common pattern, particularly for complex client groups:
- Map the structure in StructureGram — entities, ownership, control and family relationships.
- Use the diagram to identify who holds beneficial ownership or control, including through layers and trusts.
- Run identity verification and screening on those people in your existing AML tooling.
- Keep the diagram and its data as part of your file, evidencing how you understood the structure and when.
Step 2 is where StructureGram earns its place: in a group with several trusts and interposed companies, the people with real control are often not obvious from any single document, and are easy to miss in a list.
A note on scope
Australian AML/CTF reforms are extending obligations to more professional services firms. If those obligations are new to your practice, treat StructureGram as a beneficial ownership mapping and record-keeping tool within your programme — not as the programme itself. Your AML/CTF obligations, and how you meet them, remain your firm's responsibility.