AFSL Compliance Policies Drafting

An AFS licensee has various regulatory compliance obligations under the financial services laws and its AFSL conditions. Non-compliance of these obligations could have serious consequences including the suspension or cancellation of the AFSL.

A robust AFSL compliance framework starts with the drafting of AFSL compliance policies and procedures having regard to the nature, size and complexity of your particular business.   

When to consider getting new policies drafted?

A new licensee that has just been granted a new AFSL should consider having compliance policies and procedures drafted. While you would have submitted a number of proof documents such as B3 Compliance Arrangements, B3 Arrangements of Conflicts of Interest Management, B7 Risk Management System Statement, and a few other documents, these may not comprehensively cover all the key compliance requirements that you need to take into account when providing financial products and services.

It may also be worthwhile to consider having compliance policies drafted when the existing policies and procedures have become stale, i.e., they have not been reviewed or updated over an extended period of time so that it may be more efficient and cost effective to have fresh documents drafted rather than reviewing and updating the existing ones.


The precise coverage will depend on your requirements. Our AFSL Manual is typically designed to cover your key obligations under the Corporations Act and your AFSL conditions. This may include (non-exhaustive):

  • Human resources and financial resources
  • Appointment, training and termination of representatives and responsible managers
  • Monitoring and supervision of representatives
  • Conflicts of interest management
  • Breaches and breach reporting
  • Risk management
  • Promotional material management
  • Client money handling
  • Internal and external dispute resolution
  • Outsourcing
  • Record-keeping
  • Compensation arrangement
  • Registers

Our Approach

You may be able to purchase template policies online. Why should you consider working with us?

It really depends on what you are looking for. What is important is that your policies and procedures align with the nature, size and complexity of your business. Templates that can be easily purchased online are typically well-considered and comprehensive documents that take into account a wide variety of scenarios.

If you are well versed with the regulatory requirements applicable to your AFSL, it might be a good idea to purchase templated documents, but only if you go through the documents and tailor them so that they are appropriate in all the circumstances of your business.

On the other hand, if you are not familiar with the regulatory requirements, you may wish to consider having policies drafted specifically for you. At Xenia Compliance, we work closely with our clients to understand not just the products and services you offer, but also the ins and outs of your business operations, such as the human and financial resources available, strengths and weaknesses of the team, existing business systems and controls, the capacities of the back office and other infrastructure, and so on. In short, we take the time to really understand your business, so that we can leverage off such understanding when preparing policies and procedures for you.  

To find out more about how we could assist with AFSL compliance for your business, simply click here to book an obligation-free virtual coffee with our founder and director Xiaoshu Liu.