My extensive experience includes advising clients on compliance with financial services laws, agreements and promotional materials including product disclosure requirements, policy wordings, business and distribution model strategies, negotiation and preparation of authorised representative, distribution and outsourcing agreements, reviewing advertising materials, liaison with key Australian regulators, compliance programs and training materials, applying for financial services licenses and exemptions.

Career highlights

• IAG: Acted for IAG on the $1.85 billion acquisition of the Australian and New Zealand insurance underwriting businesses.
• Suncorp, Insurance Australia Group Limited and Zurich: Acted in relation to Federal Court-approved insurance portfolio transfer schemes under Pt 9 of the Life Insurance Act 1995 (Cth) and Division 3A of the Insurance Act 1973 (Cth).
• AIA, ClearView Life, and IAG: Acted in relation to the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry.
• AIA, Allianz, ClearView Life, IAG, QBE, Suncorp, Swiss RE, TAL and Westpac: Acted in relation to the post-Royal Commission reforms including Product Design and Distribution Obligations, the application of unfair contract terms to general and life insurance, the duty to take reasonable care not to make a misrepresentation and the introduction of claims handling and settling as a regulated financial service.
• Acted for a range of general insurers, life companies and wealth manages in relation to the Future of Financial Advice (FOFA) and Life Insurance Framework (LIF) reforms including the establishment of compliant remuneration structures and the end of grandfathering transition.

Education
LLB, GradCertLaw (University of Technology Sydney)

• FAR preparation for the insurance and super sectors
  

  The Financial Accountability Regime (FAR) Bill and its associated rules have been passed, setting new accountability standards for the banking, insurance, and superannuation sectors starting from March 2024, with regulators releasing detailed guidelines and transitional rules.

• Reframing financial services regulation | ALRC Final Report released
  

  The Australian Law Commission has completed its three stage review of the legislative framework for corporations and financial services regulation. Here's our overview of the Final Report.  

• Creating a separate financial services law
  

  MinterEllison has submitted a response to the Australian Law Reform Commission’s third interim report - Interim Report C.

• APRA's new operational risk standard finalised
  

  The Australian Prudential Regulation Authority (APRA) has released its long-awaited new cross industry prudential standard - CPS 230 Operational Risk Management (CPS 230) – to 'strengthen the management of operational risk across APRA’s regulated population'.  APRA has also opened consultation on draft guidance to support implementation.  Here's what you need to know.

• The unexpected impact of DDO stop orders on general insurance
  

  Questions and challenges that would arise from a stop order applying to a renewing insurance product.

    

• MinterEllison's submission on proposed reforms to the AML/CTF regime
  

  MinterEllison has made a submission to the Attorney-General’s Department on its proposals to reform the AML/CTF regime.

• Reforging financial services law
  

  The Australian Law Reform Commission has released its first interim report, with proposals that could significantly reshape financial services law. We explore the details of the report.

• Improving complaints handling
  

  ASIC proposes mandatory data reporting standards to improve internal dispute resolution processes.

   

• ASIC updates breach reporting guidance for AFS and credit licensees
  

  ASIC has released an updated version of its guidance on breach reporting (RG 78) following their own insights and industry feedback.

   

• CPS 230: Your roadmap to compliance
  

  From 1 July 2025, APRA-regulated entities must comply with CPS 230 – a new standard requiring entities to better manage operational risks and respond to business disruptions.

• Uncertainty renewed for foreign licensing relief
  

  The election of a new government has reignited significant uncertainty in the regulatory landscape for foreign financial service providers (FFSPs).

• FFSP relief extended for another 12 months
  

  ASIC has extended the current licensing exemptions for foreign financial service providers (FFSPs) by a further 12 months, until 31 March 2026.

• ASIC sends a message to 'Licensees-for-hire'
  

  This case is important for 'licensees for hire', which allow other businesses to use their licence. It is also a reminder for all AFS licensees to ensure they have sufficient resources to operate their business and in particular to oversight their authorised representatives.

• 'Reasonable’ rehashed: Judicial clarity on a licensee’s obligation to take 'reasonable steps'
  

  The Federal Court has provided clarity on what it means for a licensee to take 'reasonable steps'

• Submission to Treasury Consultation Paper on Crypto asset secondary service providers
  

  On 21 March 2022, Treasury began consultation on a licensing and custody regime for crypto asset secondary service providers. MinterEllison made a submission to the consultation paper on 27 May 2022 supporting the outlining of minimum standards of conduct by crypto asset secondary service providers and safeguards for consumers.

• FAR implementation | Financial Accountability Regime (Minister Rules) 2024 published
  

  Who is an 'accountable person' under the FAR and when will accountable entities meet the 'enhanced notification' threshold? Here's what's in the long-awaited Financial Accountability Regime (Minister Rules) 2024

• FAR transition | Regulators issue final Rules
  

  ASIC and APRA have finalised new Rules setting out what information they need from ADIs about their Accountable Persons (APs) at the 'transition point' from the BEAR to the FAR - Financial Accountability Regime (Consequential Amendments) Transitional Rules 2024 (Transitional Rules) - and confirming the information to be included in the FAR register of accountable persons -Financial Accountability Regime Act (Information for register) Regulator Rules 2024 (Regulator rules).  Here's what you need to know.

• CPS 230 | Consultation on strengthening operational risk management begins
  

  APRA has proposed a new prudential standard CPS 230, which aims to strengthen operational risk controls and monitoring, business continuity planning and the management of third-party service providers. We explore the new framework and what it means for service providers.

• New AML/CTF Bill impacts real estate sector
  

  The long-awaited Bill foreshadowing new significant AML/CTF obligations for real estate and professional services has arrived.

• Order up! ASIC expands its menu of product intervention orders
  

  ASIC made a product intervention order on 22 October that imposes conditions on the issue and distribution of contracts for difference (CFDs) to retail clients. We've summarised the key aspects of the order and provide our take on the implications.

• Response to Treasury Quality of Advice Review consultation paper
  

  MinterEllison has made a submission on the proposals in the Quality of Advice Review consultation paper released on 29 August 2022. We welcome the far reaching reforms proposed by the Review which have the potential to make personal financial product advice more accessible and affordable while reducing regulatory burden on advice licensees.

• APRA supervisory and policy priorities for H1 2024 released
  

  GRCA, operational resilience, climate and cyber included among APRA's top supervision and policy priorities for the next six months.   

• A guide on breach reporting requirements for AFS and credit licensees
  

  ASIC's new breach reporting requirements will commence on 1 October 2021. Our new guide will help you comply with the new rules.

• APRA's final guidance on CPS 230: What you need to know
  

  APRA's final guidance outlines crucial updates and the timeline for implementing operational risk management in APRA-regulated entities.

• ASIC calls on general insurers to sharpen their focus on nonfinancial risk in light of ongoing 'systemic pricing failures'
  

  ASIC REP 765 reiterates calls on all general insurers to be proactive in their approach to nonfinancial risk and in particular, to sharpen their focus on 'good product governance' in light of ongoing failures by industry to deliver on pricing promises to customers.