Caroline specialises in financial services regulation, funds management and superannuation law.
Having practised in Australia, New Zealand and the United Kingdom, including three years at a top tier global law firm in Melbourne, Caroline has a broad and deep range of global legal experience. She regularly advises Australia’s major banks, non-banking lenders, fund managers and FinTechs on their compliance with their regulatory obligations.
Caroline principally advises on:
- AFSL and ACL requirements and exemptions, licensing applications, relief applications, corporate authorised representative arrangements, compliance programs and training, in relation to most financial products, including securities, interests in managed investment schemes, derivatives and general insurance products;
- AML/CTF regulatory advice and compliance assistance, including relief applications, training, AML/CTF program development, independent reviews and reforms;
- financial product disclosure documents and advertising, including design and distribution obligations;
- payment system regulation and compliance, including payment facilitation, stored value facilities and other non-cash payment products;
- digital assets regulation, including stablecoins and NFT products;
- energy derivatives and carbon credit arrangements;
- wholesale and retail fund structuring and establishment in a range of industries (property, income, carbon credits, offshore private equity);
- breach reporting; and
- general corporate, governance and risk matters.
As a “front-end” lawyer, Caroline’s passion is the development of new and innovative financial products, to be shaped by reforms in the areas of digital assets, payments and AML/CTF. Caroline actively contributes to the development of new laws and regulations, for example through FinTech Australia’s policy committees and contributions to regulatory submissions.
Caroline is recognised by clients for having an innovative and outcome-focused mindset and she enjoys collaborating with clients, colleagues and regulators and colleagues to achieve clients’ objectives.
Specific experience examples
- Acting for one of Australia’s largest banks on financial regulatory due diligence aspects of prospective purchase of two banks.
- Acting for a SME business bank on its AFSL application, deposit offerings and other regulatory requirements.
- Acting for a number of foreign financial service providers (FFSPs) on various cross-border financial services matters, including ASIC relief application of current and proposed statutory FFSP exemptions and preparation of compliance manuals to ensure personnel compliance within scope of available relief.
- Advising a global payment provider on its AFSL application and AML/CTF requirements for provision of global payroll and contractor payment services in Australia.
- Acted on submission response by FinTech Australia members to consultation on updates to ASIC INFO 225: Digital Assets: Financial Products and Services
- Acting for a fund manager on the establishment of a wholesale managed investment scheme investing in carbon credit opportunities
- Conducting Part A independent reviews for three rural debenture issuers/lenders operating a “micro” business with largely manual processes.
- Acting for Victorian Independent Schools Superannuation Fund on its merger with Aware Super via successor fund transfer.