A Money Flow Map is a controlled diagram plus a transaction register. For every material flow it identifies the payer, recipient, legal purpose, contract, currency, account or PSP, frequency, amount range, tax/accounting treatment, owner and evidence. Its value is not a promise of faster banking; it is the ability to expose contradictions before a provider, auditor or authority does.

What belongs on the map

Start with legal entities and individuals, but do not stop at ownership. Add operational accounts, safeguarding or settlement accounts where known, payment providers, wallets used by the business, marketplaces, payroll and tax destinations. Draw only material flows and give each one an ID.

The companion register turns each arrow into data: product or service, legal basis, contract owner, invoice issuer, payer and recipient, countries, currency, expected amount and frequency, fees, conversion, tax/VAT assumption, bookkeeping code and supporting file.

  • Customer receipts and refunds
  • Supplier, contractor and payroll payments
  • Intercompany service, loan and dividend flows
  • Founder capital and shareholder withdrawals
  • Tax, VAT, marketplace and PSP settlements

Build it from evidence, not a workshop memory

Export twelve months of bank, PSP, marketplace and ledger data. Group transactions by economic purpose rather than merchant name alone. Reconcile the largest and riskiest flows to contracts, invoices and accounting. Interview finance, legal, sales and operations separately; their disagreements are findings.

Create an as-is version first. Do not draw the intended future and present it as current. Mark undocumented flows, personal-account use, unexplained third parties, country mismatches and manual workarounds. Then create a separately labelled target version with owners and dependencies.

Use four lenses for every arrow

The legal lens asks who is entitled and obliged under the contract. The tax/accounting lens asks how the flow is booked and reported. The banking lens asks whether it matches the customer profile, purpose and counterparties. The operational lens asks who initiates, approves, reconciles and can stop it.

A flow is not ready because one adviser approves one lens. For example, an intercompany payment may be contractually possible but poorly priced, booked inconsistently, unexpected by the bank or approved by the same person who initiates it.

Govern the map as a live control

Assign a document owner, version date and review trigger. Update the map after a new market, product, entity, owner, account, PSP, currency, major counterparty or material change in volume. Keep prior versions so a historical transaction can be explained with the model that existed then.

The map does not certify legality, tax compliance or bank acceptance. Each material assumption needs the appropriate professional or provider confirmation. Used honestly, it is a shared index for onboarding, audits, treasury design and incident response.

Questions clients ask

Is a Money Flow Map the same as an ownership chart?

No. Ownership shows legal interests. The flow map shows transactions, contracts, accounts, currencies, controls and evidence.

Will a map prevent a bank from blocking a payment?

No. It can improve consistency and reveal gaps, but a bank applies its own monitoring and can request more information or restrict activity.

How detailed should it be?

Detailed enough to explain every material flow without becoming a line-by-line bank statement. Use flow IDs and a register for the underlying data.

Primary sources

  1. THE A — original Money Flow Map concept
  2. EBA — Guidelines on ML/TF risk factors
  3. EUR-Lex — Directive (EU) 2015/849