About Chris Mee

Chris Mee is a leading lawyer in funds management and financial services in Australia.

Entries by Chris Mee

AML/CTF reforms: Governance and accountability under the new framework

Under the amended Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Act) and the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Rules), the reforms commencing 31 March 2026 embed governance and oversight obligations on reporting entities and require those obligations to be reflected in the AML/CTF program. AML/CTF compliance can no longer operate solely as a […]

AML/CTF reforms: New statutory requirements for AML/CTF compliance officers

From 31 March 2026, the amended Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Act) and the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Rules) impose explicit statutory requirements in relation to the AML/CTF compliance officer role. For many reporting entities, the AML/CTF compliance officer has historically operated as a functional compliance contact. Under the reformed […]

Treasury’s managed investment scheme reforms: three structural changes fund managers need to watch

Treasury has released a consultation paper, Enhancing oversight and governance of managed investment schemes, seeking feedback on a suite of reforms aimed at lifting governance standards and strengthening ASIC’s oversight of the retail managed investment scheme (MIS) sector. The policy direction in brief The reforms follow the collapse of several high-profile schemes and reflect a […]

Regulatory Review of Lead Generation Practices in the Financial Advice Sector

Advice licensees that use third-party lead generation services are facing increased regulatory scrutiny, particularly where those arrangements may contribute to inappropriate superannuation switching. ASIC has commenced a review of advice businesses that rely on lead generation models as part of its broader focus on consumer outcomes and distribution practices. Lead Generation and Compliance Risk Lead […]

AML/CTF reforms: What you need to know about the new reporting group framework

From 31 March 2026, designated business groups will cease. Entities seeking to discharge certain AML/CTF obligations on a group basis must form a reporting group under the amended Anti Money Laundering and Counter Terrorism Financing Act 2006 (Act) and the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Rules). While reporting groups may deliver operational efficiencies, […]

AML/CTF reforms: Is your program fit for the new framework?

Reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Act) and the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Rules) commence on: 31 March 2026 for current reporting entities; and 1 July 2026 for tranche 2 entities, including legal and accounting professions, real estate professionals and dealers in precious metals and stones. Although the […]

ASIC suspends AFS licence for responsible manager compliance failures

ASIC has suspended the Australian financial services (AFS) licence of MW Planning Pty Ltd until 8 June 2026 after the firm failed to appoint a replacement responsible manager following regulatory action taken against its existing responsible manager. Failure to replace responsible manager ASIC banned MW Planning’s responsible manager, Robert John Tohill, on 25 August 2025. […]

ASIC updates guidance on managing conflicts of interest in financial services

ASIC has released an updated version of Regulatory Guide 181: AFS Licensing – Managing Conflicts of Interest (RG 181), replacing guidance that had remained largely unchanged since 2004. While the underlying statutory obligation has not been amended, the updated guide significantly clarifies how ASIC expects Australian financial services (AFS) licensees to identify and manage conflicts […]

ASIC releases catalogue of key obligations for private credit funds

ASIC has issued a consolidated catalogue of the core legal obligations and regulatory guidance that applies to trustees, responsible entities and managers operating private credit funds. The catalogue is designed to drive uplift across a sector that continues to expand in scale, complexity and investor exposure. Its release reflects ASIC’s intensified supervisory posture outlined in […]

ASIC Issues interim stop order against FXCM over target market deficiencies

The Australian Securities and Investments Commission (ASIC) has issued an interim stop order preventing FXCM from issuing contracts for difference (CFDs) to retail clients due to deficiencies in its target market determination (TMD). Reason for action ASIC took action after identifying that FXCM’s TMD inappropriately included investors with a medium risk appetite within the target […]