Complex ownership diagrams: when to stop and enhance

People search “complex structure CDD” when an accountant is on the third page of a diagram of companies and a trust and wants permission to stop. Checked against AUSTRAC’s enhanced customer due diligence reform guidance on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. What enhancement involves is on enhanced customer due diligence. How a trust is traced is on beneficial owner of a trust. The sector map is /tranche-2.

Stop at people, or escalate

A complex structure is a chain of companies and trusts between the customer and the humans. You are finished with the chain when the individuals who own or control are identified as the program requires. You are not finished because the page is full, because a nominee company sounds important, or because the client says the diagram is commercially sensitive. If you cannot get through, that fact is the risk.

Enhancement is the program’s response: more questions, more evidence, a higher rating, or a decision not to provide the service. It is not a neater chart. This page does not set a maximum number of layers and does not list the documents enhancement always requires.

• Name the stop rule. Individuals identified, or cannot identify. Write which one this file is.
• Do not stop at a company. A box with an ACN is a step. The beneficial owners are people.
• Treat opacity as a factor. A client who will not explain a layer has given you a reason to enhance or decline, not a reason to sketch past it.
• Verify who you reached. Each individual the program names is a check. The diagram is not the check.

Four places a diagram pauses

The reviewer should see one of these four notes on the file. Anything else is a picture without a decision.

Where the diagram page stops

This page is when to stop tracing and when to enhance. It is not the content of enhanced due diligence and it is not a trust trace. Those are enhanced customer due diligence and beneficial owner of a trust. FreeAML does not draw the structure and does not apply the enhanced path.

The firm suite is A$0. Each required check is client-pays.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. The firm suite does not include drawing the diagram or deciding that the structure is enhanced. Confirm the live amounts on FreeAML pricing. FreeAML does not draw your ownership diagram or tell you when to enhance.

Frequently Asked Questions