Services
AFSL Advisory provides advisory services across the full AFSL lifecycle. Whether you are
applying for a new licence, acquiring an existing one, or strengthening the compliance arrangements of
an operating business, we deliver structured, practical advice that is aligned to your authorisations,
operating model and commercial objectives.
AFSL Applications
We provide end-to-end advisory support for businesses applying to ASIC for an Australian Financial
Services Licence. Our role is to ensure that the application is comprehensive, internally consistent, and
supported by documentation that demonstrates the applicant’s capacity to meet the general
obligations imposed on licensees under Part 7.6 of the Corporations Act 2001.
Key deliverables:
- Identification and definition of the appropriate AFSL authorisations based on the applicant’s proposed financial services and products.
- Responsible manager assessment, evidence assembly and gap remediation.
- Preparation of the core application documents including the compliance framework, organisational competence statement, business description and financial projections.
- Drafting of compliance policies, procedures and governance documentation required to support the application.
- Management of the application process, including coordination of responses to ASIC
information requests.
AFSL Acquisitions
Acquiring an existing AFSL through a change of control of the licence-holding entity can provide a more
expedient pathway to market than a new application. We advise buyers through the identification,
assessment and completion of AFSL acquisitions, with a focus on regulatory due diligence, licence scope
alignment and post-completion transition planning.
Key deliverables:
- Assessment of the target licence’s authorisations, conditions and compliance history against the buyer’s intended financial services.
- Regulatory and operational due diligence covering governance, key persons, outsourcing, financial position and incident history.
- Identification of required licence variations, responsible manager changes and compliance framework uplift.
- Preparation of a structured transition plan covering the first 30, 60 and 90 days following ciompletion.
- Support with ASIC change of control notifications and any consequential licence variations.
Compliance and Ongoing Support
Licensed businesses face ongoing obligations in respect of compliance, governance, reporting and risk
management. We design, implement and maintain compliance frameworks that are proportionate to
the licensee’s authorisations and operating model, and that can be operated effectively as part of the
business’s day-to-day activities.
Key deliverables:
- Design and documentation of compliance frameworks including compliance plans, risk management frameworks, monitoring programs and reporting arrangements.
- Policy drafting and periodic review across all core obligation areas: conflicts, complaints, incidents, outsourcing, record-keeping, training and financial requirements.
- Compliance monitoring and testing, including thematic reviews and file sampling.
- Breach and incident management support, including significance assessments and ASIC reporting obligations.
- Board and senior management compliance reporting.
Regulatory Strategy for Fintech
Technology-led financial services businesses frequently operate across multiple regulatory boundaries.
We assist fintech businesses to identify which of their activities constitute financial services, to
determine the AFSL authorisations required, and to design a practical, sequenced approach to market
entry that accounts for product development timelines and commercial priorities.
Key deliverables:
- Regulatory mapping of proposed products and services against the financial product and financial service definitions in the Corporations Act.
- Assessment of available exemptions, transitional relief and alternative licensing pathways (including corporate authorised representative arrangements).
- Design of a staged licensing strategy aligned to the client’s product roadmap and capital position.
- Compliance framework design for novel or non-traditional operating models.
- Support with ASIC pre-application engagement where appropriate.
How We Work
01
Scope and Plan
We define the engagement scope, confirm the licensing pathway, and agree
deliverables, timelines and responsibilities.
02
Assess and Build
We conduct the required analysis, identify gaps and risks, and prepare
documentation to the required standard.
03
Execute and Respond
We manage the submission, acquisition or implementation process, coordinating inputs and responding to regulatory requests.
04
Operate and Improve
We support the transition to business-as-usual operations and provide
ongoing advisory as the business evolves.
Discuss Your Requirements
Tell us about your business, the financial services you intend to provide, and where you are in the
licensing process. We will respond within one to two business days.