For this client, we provided specialist resources to help remediate a number of items related to their AFSL obligations, including governance, website representations, policies/procedures, onboarding of clients (AML) and conflicts of interest.

This was a compliance due diligence on a target Australian market participant whereby we reviewed compliance arrangements and documents in the due diligence phase of a potential purchase, including identifying red flags and areas for enhancement.

We were appointed and approved by ASIC as the Independent Expert to review and assess First Prudential’s compliance arrangements as they relate to having adequate policies/procedures, controls and risk management systems in place for detecting, escalating and reporting actual or potential market misconduct by its clients, including entire compliance framework, Automated Order Processing filters and post-trade surveillance.

This client undertook a management buy-out and full separation from their banking parent. Our work on this project included:

• Building the client’s compliance and operations frameworks, obligations matrix, all controls, policies and operational procedures
• Assisting the client to re-paper and onboard 8,000 clients
• AML/CTF program development, documentation and implementation
• AML risk assessment of client accounts
• Integration of their new technology platform incorporating Australian regulatory requirements

We were appointed as the Independent Expert by the client and approved by ASIC and ASX to carry out a review, assessment and report on remediation related to AFS Licence conditions imposed on the client by ASIC, including compliance framework and policies, pre-trade filters, post-trade surveillance, escalation and governance.

Read the published Summary Report.

We were appointed as independent regulatory advisor to review and assess on an annual basis the adequacy of compliance arrangements related to the ongoing regulatory obligations of the client and its advisors, including best interest duties.

This client sought our assistance with their AFSL application as well as ongoing ad hoc compliance services, including quarterly reviews.

As Independent Expert, we carried out a review and assessment of the client’s research division, focusing on regulatory and conduct risks associated with potential conflicts and the handling of non public, price sensitive information.

We provided this client with a specialist team to scope and build an obligations matrix, including plain English equivalents, across five international jurisdictions covering the clients OTC transaction reporting obligations.

This client was reviewing their own technology/operations resilience and we provided a specialist team to deliver an obligations matrix (incl. Corporations Act and ASX Operating, Clearing and Settlement Rules and Rules Procedures) and test the technology, regulatory and operations resilience for all controls across the trading, clearing and settlement parts of the business.

We coordinated and lodged the applications for this client to become an ASX and Cboe (formerly Chi-X) trading participant. Services including preparation and lodgement of the applications forms, policies and procedures for trading rules (Corporations Act, ASIC Market Integrity Rules, ASX / Cboe Operating rules) and capital requirements.