AFSL Compliance and Ongoing Support
Practical, risk-based support to help you meet ongoing obligations—uplifting your compliance programme, monitoring and testing, incident and breach handling, training, and governance reporting.
Holding an Australian Financial Services License imposes a continuing set of obligations
on the licensee. These obligations are prescribed by the Corporations Act 2001, the Corporations
Regulations 2001, applicable ASIC regulatory guides and class orders, and the specific conditions
imposed on the individual licence. Non-compliance can result in regulatory action including licence
suspension or cancellation, civil penalties, and reputational harm.
AFSL Advisory designs, implements and maintains compliance frameworks that are proportionate to the
licensee’s scale, complexity and risk profile. We focus on creating arrangements that can be operated as
part of the business’s normal activities, rather than compliance structures that exist only on paper.
ONGOING SUPPORT
What we cover
We help you define your ongoing obligations at a high level, uplift your compliance programme, and keep it operating through monitoring, testing and clear governance reporting—aligned to your authorisations, products and distribution model.
Compliance Plan Design and Annual Review
A compliance plan is the foundation of an effective compliance framework. It documents the licensee’s key obligations, the controls in place to meet them, the monitoring program, and the process for identifying and reporting breaches. AFSL Advisory designs compliance plans that are tailored to the licensee’s specific authorisations and operating model, and that satisfy ASIC’s expectations under RG 104. We conduct annual reviews to ensure the plan remains current as the business evolves and regulatory requirements change.
Risk Management Framework
AFSL holders are required to have adequate risk management systems under section 912A of the Corporations Act. We design risk management frameworks that identify the key regulatory, operational and financial risks applicable to the licensee’s business, document the controls in place to manage those risks, and establish a process for monitoring and reporting on risk exposures to senior management and the board.
Monitoring and Testing Programs
A compliance framework is only effective if it is actively monitored. We design and implement monitoring and testing programs that provide the licensee with ongoing assurance that its compliance controls are operating as intended. This includes thematic reviews, file sampling, transaction testing and periodic assessments of key obligation areas. Results are documented and reported to senior management, with findings and remediation actions tracked through to completion.
Conflicts Management
Managing conflicts of interest is a core obligation under section 912A. We design conflicts management frameworks that identify the conflicts relevant to the licensee’s business model, document the controls in place to manage or avoid those conflicts, and establish disclosure and escalation procedures. We also assist with the implementation of conflicts registers and periodic conflicts assessments.
Complaints Handling
Licensees are required to have an effective complaints handling process that complies with RG 271 and to be a member of the Australian Financial Complaints Authority (AFCA). We design complaints handling policies and procedures that meet these requirements, train staff on complaint identification and escalation, and assist with the preparation of internal and external dispute resolution documentation.
Record-Keeping and Document Management
The Corporations Act and ASIC’s regulatory guides impose specific record-keeping obligations on licensees, including requirements to retain records for prescribed periods and to make them available to ASIC on request. We document the licensee’s record-keeping obligations across all authorisation areas, design a record-keeping policy and procedure, and assist with the implementation of document management systems that satisfy these requirements.
Outsourcing Oversight
Licensees cannot outsource their regulatory obligations. Where material functions are performed by third-party service providers, the licensee remains responsible for ensuring those functions are performed in compliance with its licence conditions and the Corporations Act. We design outsourcing frameworks that identify material service providers, document oversight arrangements, and establish due diligence and monitoring processes proportionate to the risks involved.
CPD and Training Programs
Licensees are required to ensure their representatives are adequately trained and competent to provide the financial services covered by the licence. We design CPD and training frameworks that satisfy ASIC’s requirements under RG 105, document training obligations for each representative category, and assist with the implementation of training registers and annual CPD planning.
Board and Committee Compliance Reporting
Senior management and the board require regular, structured compliance reporting to discharge their oversight responsibilities. We design compliance reporting frameworks that provide the board and relevant committees with clear visibility over the licensee’s compliance posture, key risks, monitoring outcomes, breach history and regulatory developments. Reports are structured to support informed decision-making without overwhelming recipients with operational detail.
ASIC Engagement and Regulatory Correspondence
Licensees are required to notify ASIC of a range of events and changes, including changes to responsible managers, significant breaches, and changes to the licensee’s business. We assist licensees to identify their notification obligations, prepare required notifications and correspondence, and manage ongoing engagement with ASIC including responses to surveillance inquiries and requests for information.
Key focus areas for ongoing compliance
A structured approach to ongoing compliance—designed to evidence reasonable steps, support decision-making, and provide clear reporting to your board and responsible managers.
Ongoing obligations & monitoring
Monitoring plans, testing, thematic reviews and reporting that match your business model and risk appetite.
Training & competence
Role-based training, competence frameworks and attestations for representatives and staff—supported by practical materials and refresher sessions.
Incident & breach readiness
Incident triage, materiality assessment, documentation and escalation pathways—plus remediation governance and evidence retention.
Board reporting & oversight
Board and RM reporting packs, policy review cycles, registers, and oversight of outsourcing, representatives and third parties.