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The review of nearly 1,500 funds with a combined value approaching $1 trillion highlighted areas where compliance plans could be enhanced to better address core regulatory duties. In particular, many plans lacked sufficient detail or did not fully incorporate obligations under the Design and Distribution Obligations (DDO), Internal Dispute Resolution (IDR), and Reportable Situations (RS) frameworks. In some instances, DDO wasn’t mentioned at all – indicating that these documents may not have been properly updated since the regime’s introduction in 2021.
ASIC’s findings underscore the importance of maintaining compliance plans that are current, comprehensive, and aligned with evolving regulatory expectations.
Compliance plans are not just a regulatory formality – they are a critical component of the governance framework designed to protect retail investors. ASIC’s findings revealed that many REs may not be meeting their obligations under the Corporations Act 2001, raising concerns about governance and risk management.
ASIC has contacted several REs and is investigating others for potential breaches. All REs are urged to:
This review is a timely reminder that compliance plans should be living documents – actively maintained, regularly reviewed, and aligned with evolving regulatory expectations. For REs, this is not just about avoiding enforcement action; it’s about demonstrating a commitment to investor protection and sound governance.
At Grant Thornton, we work with fund managers to strengthen compliance frameworks and embed regulatory obligations into day-to-day operations. If you’d like to discuss how these findings may impact your business, please get in touch.
Proactive stress testing to manage macroeconomic risk, strengthen financial stability and banking
In July 2025, we wrote about the Federal Court’s decision in S.N.A Group Pty Ltd v Commissioner of Taxation [2025] FCA 240, which was widely seen as a ‘commercial reality’ endorsement for inter entity service fee arrangements in closely held groups – where documentation is known to be imperfect.
The AUSTRAC AML/CTF Starter Programs provide a structured pathway to achieving AML/CTF compliance that will significantly reduce the effort and cost of AML/CTF compliance for entities required to meet AML/CTF obligations under Tranche 2.
