---
title: "Trace the individuals who own or control a customer"
url: "https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/trace-the-individuals-who-own-or-control-a-customer"
type: "task"
site: "AI Law Framework"
id: "A52OB-SF20261022-16"
practice_area: "AML/CTF — the practice as a reporting entity"
tier: "yellow"
lawyer_review: "required"
last_reviewed: "2026-10-22"
---

# Trace the individuals who own or control a customer

> From the structure chart, company extract, trust deed or partnership agreement, list each person named and the percentage or office the document gives them.…

Canonical page: https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/trace-the-individuals-who-own-or-control-a-customer  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [AML/CTF — the practice as a reporting entity](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | From the structure chart, company extract, trust deed or partnership agreement, list each person named and the percentage or office the document gives them. Stop at the first entity that is not an individual and leave the beneficial-owner names blank. |
| What the lawyer must review | The lawyer decides who the beneficial owners are. Act section 5, as the page states it, means an individual who directly or indirectly owns 25 percent or more of the customer, or controls the customer. The chain is followed until those individuals are identified. Control under section 11 does not require ownership. For a body corporate the page lists voting power of more than 50 percent, holding more than 50 percent of the issued share capital with the exclusions the page states, control of the board, or practical influence over financial and operational policies. For a person who is not a body corporate, the page lists control of the governing body, or the same practical influence. Section 28 requires the practice to know how the customer is owned, controlled and managed. The customer on this page is a person other than an individual. This trace is of the customer. It is not the decision about whether the practice itself is in a reporting group. |
| Written for / versions | 1 jurisdiction versions below |

## Checking plan

**Line-by-line review**

Review the complete output at the level of each line; check facts, meaning and omissions.

- What the AI does: From the structure chart, company extract, trust deed or partnership agreement, list each person named and the percentage or office the document gives them. Stop at the first entity that is not an individual and leave the beneficial-owner names blank.
- What the lawyer does: The lawyer decides who the beneficial owners are. Act section 5, as the page states it, means an individual who directly or indirectly owns 25 percent or more of the customer, or controls the customer. The chain is followed until those individuals are identified. Control under section 11 does not require ownership. For a body corporate the page lists voting power of more than 50 percent, holding more than 50 percent of the issued share capital with the exclusions the page states, control of the board, or practical influence over financial and operational policies. For a person who is not a body corporate, the page lists control of the governing body, or the same practical influence. Section 28 requires the practice to know how the customer is owned, controlled and managed. The customer on this page is a person other than an individual. This trace is of the customer. It is not the decision about whether the practice itself is in a reporting group.
- Who reviews: Responsible lawyer with competence in the matter
- Basis: Practical workflow informed by the linked primary sources; the traffic light and working checks are editorial guidance, not a court classification.
- Why: The level reflects what the work is, the consequence of an error, and how much of the output the lawyer must independently re-derive.

## Checks the lawyer makes

1. Follow each holder of 25 percent or more until the holder is an individual.
2. Apply the control tests as well as the percentage. A person can control without owning.
3. For share capital, apply the exclusions the page states before treating a holding as more than 50 percent.
4. Do not use this chain to decide whether the practice and its related entities are one reporting group.

## Notes

- These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.

## Sources

- [AUSTRAC: Determining ownership and control structures](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/additional-guidance/determining-ownership-and-control-structures) (checked 2026-10-22)

## Jurisdiction versions

| Jurisdiction | Level |
| --- | --- |
| [United States](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/trace-the-individuals-who-own-or-control-a-customer/united-states.md) | Yellow |

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*