Compliance isn't optional and it isn't static. Whether you operate under our licence as an authorised representative or hold your own AFSL, Provenance provides a maintained compliance framework, ongoing monitoring, and support for your regulatory reporting — so your obligations are met to standard without standing up a full compliance function in-house.
Your compliance obligations
Australian financial services licensees carry continuing obligations under the Corporations Act 2001 (Cth) — to provide financial services efficiently, honestly and fairly, to maintain adequate risk-management and compliance arrangements, to keep representatives trained and compliant, and to report certain matters to regulators (the general obligations in s 912A and related provisions). Authorised representatives must operate within their authorised scope and meet the same standards within it.
These obligations are ongoing, and the regulatory bar is rising — particularly for the wholesale funds and schemes sector, where ASIC has signalled increased oversight.
New to AFSL obligations? See our guide to the licensing pathways.
The compliance framework
A maintained framework, kept current as the rules change:
- Compliance policies and procedures
- Compliance registers — breaches, conflicts, complaints and CPD
- Ongoing monitoring and supervision of conduct
- A training and CPD framework
- Conflicts-of-interest management (consistent with ASIC's guidance, including RG 181)
- A risk-management framework
Regulatory reporting
Support to identify, prepare and lodge the reports your obligations require:
- Reportable situations (breach reporting) — identifying and reporting reportable situations to ASIC within the required timeframe under the reportable situations regime (s 912DAA; RG 78).
- Annual licensee reporting — financial statements and auditor's reports for AFSL holders (FS70 / FS71; s 989B).
- Ongoing notifications — changes to licence details, key persons and authorisations.
- AML/CTF obligations — AUSTRAC reporting where you are a reporting entity, with the AML/CTF reforms taking effect through 2026.
- Emerging wholesale-scheme reporting — as ASIC's private-markets reforms land, we help you stay ahead of new obligations.
How it works with Provenance
Two ways to run on the framework — under our AFSL as an authorised representative, or alongside your own licence.
| Authorised representative (under our AFSL) | Hold your own AFSL | |
|---|---|---|
| Compliance framework | Part of operating under AFSL 487419 — provided and maintained for you. | Outsourced framework that sits alongside your own licence. |
| Monitoring, training & reporting | Built in. | Provided as outsourced support. |
| Regulatory reporting | The licensee handles certain reporting; we support the rest. | The reporting obligation is yours; we support preparation and lodgement. |
| Where the obligation sits | With the licensee; you operate within your authorised scope. | With you, as the licensee. |
| Start here | Authorised Representative Onboarding | Runs alongside your existing AFSL. |
What's included
- The compliance framework, policies and procedures
- Compliance registers — breaches, conflicts, complaints and CPD
- Ongoing monitoring and supervision of conduct
- A training and CPD framework
- Conflicts-of-interest and risk-management frameworks
- Regulatory-reporting support
Your responsibilities
Who it's for
-
Investment Managers →
Launch or relocate a wholesale strategy under an established AFSL.
-
Corporate Advisors →
Advise and transact for wholesale clients under our licence.
-
Operational Governance →
Governance, risk and operating-standard frameworks.
Frequently asked questions
What is the reportable situations regime?
It's the obligation on AFS licensees to report certain “reportable situations” — including significant breaches and likely breaches of core obligations — to ASIC within the required timeframe. We help you identify, assess and lodge these.
Do you report to ASIC on my behalf?
It depends on your structure. For authorised representatives, the licensee handles certain reporting and we support the rest; for AFSL holders, the reporting obligation is yours and we support preparation and lodgement. The obligation always sits with the obligation-holder.
Does this remove my compliance obligations?
No. The framework supports your compliance — it does not replace your obligations. As an authorised representative or licensee, you remain responsible for compliance within your authorised scope or under your licence.
Do you handle AML/CTF?
We support AML/CTF obligations where you are a reporting entity. The regime is reforming through 2026, so scope and timing should be confirmed for your circumstances.
Is this only for wholesale clients?
Yes — Provenance's framework is for financial services to wholesale clients only.