Compliance Policy Management Lawyers for AFSL Licensees & Fund Managers
Curated policy suites, a dedicated client portal & daily regulatory monitoring from our funds & financial services lawyers.
- Policy suite curated to your licence, systems, culture & requirements
- Dedicated client portal with linked registers & a critical event calendar
- Daily monitoring of ASIC, APRA, AUSTRAC, ATO, Treasury, OAIC, ACCC & court releases
- Every proposed amendment reviewed & approved by GRM LAW before you are notified
Our Compliance Policy Management Services
AFSL licensees, corporate authorised representatives, responsible entities, trustees and fund managers are required to hold a policy suite that matches their licence and business model, and to keep it current as regulators publish new guidance, instruments and decisions. GRM LAW supplies the suite, curates each policy to the client, licenses it through a dedicated client portal, monitors the sources daily and approves every amendment. Our compliance policy management services include:
01. Curated Policy Suite
We supply a standard suite of policies and curate each one to your systems, culture and requirements, separating the core clauses that stay fixed from the clauses open to client customisation.
- Identifying which policies are required for your licence, products & business model and which are optional, from incident & breach reporting, conflicts (including gifts), complaints, IT resources & training through to credit, enterprise borrowing, responsible investment & document retention policies
- Holding core policy content constant and scheduling the client-specific settings for your input, such as the gift threshold in a conflicts of interest policy or the risk descriptions, ratings, mitigators & named owners in a risk management statement
- Embedding version control and a record of the people at your business authorised to sign off amendments, with every change subject to GRM LAW approval
02. Client Portal, Registers & Critical Event Calendar
Your suite is licensed to you on a dedicated client portal, linked to the registers each policy relies on and to a critical event calendar built for your obligations.
- Unlimited access to the current version of every policy in your suite for your directors, compliance staff & representatives
- Links from each policy to its associated registers, including breach & incident, conflicts & gifts, complaints, training & policy-specific registers
- A dedicated critical event calendar so recurring reporting, review & renewal obligations are diarised & acted on
03. Daily Regulatory Monitoring
We monitor the sources that change your obligations every day and read each release against your policy suite.
- ASIC media releases, consultation papers, regulatory guide updates, reports, information sheets, forms & legislative instruments
- APRA, AUSTRAC, the ATO, Treasury, the Office of the Australian Information Commissioner, the ACCC, the Office of Impact Analysis & ministerial releases in the financial services portfolio
- Federal & Supreme Court decisions, federal & state tribunal decisions, industry body releases from the Financial Services Council, the Australian Accounting Standards Board, the Australian Property Institute & RICS, and legal publishers & law firm bulletins
04. Lawyer-Approved Amendments & Notification
Each proposed amendment is drafted, reviewed and approved by GRM LAW before it reaches your suite, and you are notified of every change.
- Proposed amendments reviewed against the core clauses & your client-specific settings, then approved or amended by GRM LAW
- Notification of each amendment, or of a proposed amendment where a client-specific clause needs your input & sign-off
- Unlimited updates under a periodic retainer, with optional 2 to 4 hour policy training & an online quiz with a pass threshold for your people
Who We Act For
GRM LAW’s funds & financial services lawyers act as long-term counsel to holders of an Australian Financial Services Licence and to the fund operators, representatives and advisory businesses that operate under one, including:
AFSL Licensees
Holders of an Australian Financial Services Licence maintaining the policy suite, registers & training that sit behind the licence.
Corporate Authorised Representatives & ARs
Corporate & individual authorised representatives operating under a licensee’s compliance framework & reporting structure.
Fund Managers & Investment Managers
Businesses that market themselves as a funds management enterprise and run mandates for wholesale investors.
Managed Investment Scheme Operators
Entities offering one or more managed investment schemes, registered or wholesale, to investors.
Responsible Entities & Trustees
Entities operating registered & wholesale schemes and holding scheme property on trust for investors.
Private Credit & Debt Funds
Managers running secured lending, bespoke credit facilities & debtor finance strategies for wholesale investors.
Property & Development Funds
Sponsors raising wholesale capital for site acquisitions, construction & development projects.
Financial Advisory Businesses
Entities offering financial advisory services with conflicts, complaints & training policies to maintain across their representatives.
Discuss Your Policy Suite & Regulatory Updates
Our funds lawyers will contact you to discuss your current policies & outline next steps.
What Our Clients Say
How The Process Works
01.
Scoping & Policy Selection
We confirm your licence profile, products & investors, identify the policies required for your business & the optional policies worth adopting, and mark the clauses open to customisation.
02.
Curation & Sign-Off
We curate each policy to your systems, culture & requirements, record the people authorised to approve amendments and place the suite under version control with GRM LAW sign-off.
03.
Portal, Registers & Calendar
We load the suite to your dedicated client portal, link each policy to its registers & build your critical event calendar.
04.
Monitoring, Updates & Training
We monitor ASIC, APRA, AUSTRAC, ATO, Treasury, OAIC, ACCC & court releases daily, approve each amendment, notify you of every change under your periodic retainer & deliver optional policy training with an online quiz.
Discuss Your Policy Suite & Regulatory Updates
Our funds lawyers will contact you to discuss your current policies & outline next steps.
Why Choose GRM LAW
01. One Curated Suite Per Client
Every policy carries core clauses that stay fixed and client-specific settings curated to your business, so the suite reads as yours and still meets the requirements of your licence.
02. Daily Regulatory Monitoring
We read ASIC, APRA, AUSTRAC, ATO, Treasury, OAIC, ACCC, court & tribunal releases and industry body publications every day against your suite.
03. Lawyer-Approved Amendments
No amendment reaches your suite until GRM LAW has reviewed & approved it, and your authorised people sign off the client-specific clauses.
04. Portal, Registers & Critical Event Calendar
Your directors, compliance staff & representatives work from one portal that links each policy to its registers & diarises every recurring obligation.
05. Partner-Led Wholesale Focus
Gavin McInnes personally supervises all funds & financial services work for wholesale funds, private credit & property funds, responsible entities & AFSL licensees across Australia.
Meet Gavin McInnes
As the founder of GRM LAW, Gavin McInnes personally supervises all funds & financial services work, including the policy suites, registers & critical event calendars that wholesale funds, AFSL licensees, responsible entities & trustees are required to hold. His practice covers AFSL governance, RG 166 financial resources & the documentation behind private credit & property funds.
Gavin is an Accredited Specialist in Business Law. Every amendment to a client’s policy suite passes through GRM LAW for review & approval before it is released to the client portal, so the suite reflects the current regulatory position and the settings agreed for that client.
Recognition & Awards
Compliance Policy Management Essentials
Required & Optional Policies
Some policies are required for an AFSL or wholesale licence and some are optional. Under s912A of the Corporations Act 2001 (Cth) a licensee must comply with the financial services laws, maintain adequate risk management systems and ensure its representatives are adequately trained. Which policies are core for your business depends on your licence authorisations, products & investors.
Core Clauses & Client Customisation
Each policy carries core clauses that are held constant and clauses scheduled for client-specific settings, such as the gift threshold in a conflicts of interest policy or the risk descriptions, ratings, mitigators & named owners in a risk management statement. Every customisation is recorded under version control, signed off by the people your business has authorised and approved by GRM LAW.
Why a Policy Suite Drifts
ASIC publishes media releases, consultation papers, regulatory guide updates, information sheets & legislative instruments continuously, and APRA, AUSTRAC, the ATO, Treasury, the OAIC, the ACCC and the courts add to the flow. A policy states the position at the date it was written. Daily monitoring and lawyer-approved amendments keep the suite aligned with the current position.
Registers, Calendar & Training
A policy operates through the registers it references and the dates it sets, so the suite is linked to its registers and to a dedicated critical event calendar on the client portal. A 2 to 4 hour training session on financial services regulation and the policies, with an online quiz and a pass threshold, evidences that your people know the policies they work under. Quiz results are retained.
Discuss Your Policy Suite & Regulatory Updates
Our funds lawyers will contact you to discuss your current policies & outline next steps.
Legal & Compliance Insights
Books By Gavin McInnes
Practical guides on structuring, asset protection and private credit in Australia.
Protect Your Assets
A plain‑English guide to protecting your home, business interests and investments under Australian law. Written for business owners, professionals and families who want to keep what they’ve built safe from avoidable risk.Â
Private Credit In Australia (Coming Soon)
A forthcoming guide to structuring, documenting and managing private credit transactions in the Australian market, written for lenders, sponsors and their advisers.Â
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