Financial Services Compliance Programs & AML/CTF Management

Comprehensive compliance program development and management services for crypto businesses, AFSLs, ACLs, and financial services providers. Holley Nethercote delivers end-to-end compliance support including policy development, AML/CTF program implementation, ongoing compliance management, training, regulatory reporting, and compliance documentation.

AML/CTF Program Implementation

Specialized AML/CTF compliance services for reporting entities including digital currency exchanges, remittance businesses, financial institutions, and entities subject to Australia's anti-money laundering regime. Services include AML/CTF program development and implementation, customer due diligence (CDD) and enhanced due diligence (EDD) procedures, suspicious matter reporting (SMR) and threshold transaction reporting (TTR), ongoing customer due diligence (OCDD), risk assessments, and AUSTRAC reporting compliance.

Holley Nethercote chairs Blockchain Australia's AML & Financial Crime Committee and provides specialized guidance for virtual asset service providers on travel rule compliance, transaction monitoring for crypto businesses, and implementing AML/CTF controls for decentralized finance (DeFi) activities. Services address Tranche 2 reforms affecting accountants and lawyers commencing in 2026.

AFSL/ACL Compliance Management

Comprehensive compliance services for Australian Financial Services Licensees and Australian Credit Licensees covering all general licensing obligations under s912A including appointments, training, outsourcing, breach reporting, dispute resolution, and risk management. Services include compliance reviews (culture and governance assessments following Royal Commission recommendations), end-to-end advice delivery reviews, compliance committee support, and ongoing compliance program management.

The firm's preventative-law approach focuses on keeping clients out of court and away from regulatory scrutiny through proactive compliance and strategic risk management. This includes licensee policy development, structuring and growth strategies, and compliance frameworks tailored to different financial services sectors including crypto businesses, fintechs, payments businesses, and advice providers.

Compliance Documentation and Templates

Comprehensive library of compliance templates, policies, procedures, and legal documents through HN Documents portal. Services include customizable compliance policies (breach reporting, conflicts of interest, complaints handling, risk management), financial services disclosure templates (FSGs, SOAs, PDSs), authorised representative agreements, compliance manuals, and operational procedures. Templates cover design and distribution obligations (DDO), target market determinations (TMDs), internal dispute resolution (IDR), financial resources requirements, and competence frameworks—all regularly updated to reflect current ASIC expectations.

Compliance Training Programs

Industry-leading training for Responsible Managers, compliance staff, and directors delivered through highly interactive, technology-enabled methods including gamified tools, live role-plays, and group workshops. Training covers ASIC Regulatory Guides RG 105 and RG 206, responsible manager obligations, compliance frameworks, breach reporting, dispute resolution, and industry-specific compliance requirements. Specialized AML/CTF training addresses customer due diligence, suspicious matter reporting, AUSTRAC obligations, and crypto-specific AML/CTF risks including travel rule compliance and blockchain transaction monitoring.

Regulatory Reporting and Defense

Ongoing support for regulatory reporting obligations including breach reporting to ASIC and AUSTRAC, responding to regulatory inquiries and surveillance activities, managing regulatory investigations, and defending enforcement proceedings. The firm's lawyers include former senior ASIC staff and AFCA personnel who understand regulatory processes from the inside, enabling practical advice on remediation, compliance improvements, and managing regulatory relationships.

Why Choose Holley Nethercote

With over 30 staff across Melbourne and Sydney offices, Holley Nethercote combines technical compliance expertise with practical, preventative-law focused guidance. The firm was heavily involved in consulting with AUSTRAC during creation of Australia's Digital Currency Exchange regime and acts for some of the world's largest digital currency exchanges, providing unmatched Australian regulatory experience from policy development through practical implementation.