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Expert AFSL Responsible Manager recruitment

Connecting AFSL holders and applicants with elite Responsible Manager talent, vetted by AFSL lawyers.

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RM Recruitment by AFSL House

HOW WE DO IT

The right RM for your AFSL, the perfect role for your expertise

Watch how AFSL House connects licence holders with top-tier Responsible Manager talent: a meticulous, proven process that fast-tracks AFSL applications and variations.

BY THE NUMBERS

RM recruitment, by the numbers

SERVICE LINE

RM Recruitment

We connect AFSL holders and applicants with qualified, ASIC-ready Responsible Managers.

Responsible Manager placements facilitated

0 +

Average RM tenure

0 yrs

INDUSTRIES WE SERVE

Funds Management
Crypto
Payments
Brokers
Fintech
Insurance

HOW IT WORKS

Recruit an RM in 4 steps

Find your next RM role in 4 steps

A meticulous, proven process that connects AFSL holders with top-tier Responsible Manager talent and fast-tracks your application or variation. 

1

Tell us your needs

Complete our brief so we understand your licence authorisations, business model and the RM competencies ASIC will expect you to demonstrate.

2

Curated shortlist

We match you with pre-screened RM candidates whose background, licensing history and sector experience align with your specific authorisations.

3

Legal vetting & interviews

Every candidate is reviewed by an AFSL lawyer against ASIC’s RG 105 requirements, then introduced to you for interview and selection.

4

Appointment & onboarding

We manage the appointment end to end: engagement terms, ASIC Form FS20 notifications and a smooth, compliant transition.

1

Register your profile

Complete our Profile Registration Form with your qualifications, experience and the authorisations you are competent to oversee.

2

Competency review

An experienced AFSL lawyer reviews your background against ASIC’s RG 105 options to confirm the roles you are well-suited to.

3

Matched to roles

We introduce you to AFSL holders and applicants whose licence authorisations and sector align with your expertise.

4

Placement & support

We facilitate engagement terms and assist with ASIC Form FS20 notifications, supporting you through a smooth appointment.

Headshot Peter Hagias, Senior Lawyer of AFSL House

Peter Hagias, Founder

OUR FIRM

Who we are

In a regulated industry, the wrong partner can cost you your licence, your timeline and your sleep. AFSL House was built to be the opposite. Since 2020, founder and senior financial services lawyer Peter Hagias has led a team trusted by financial services businesses of every size. We take the stress and guesswork out of operating in a regulated environment.

We are more than a law firm. Alongside our 100% AFSL application success rate, we help you meet your ongoing regulatory obligations and commercial objectives with a number of complementary services. So whatever you need to launch your business and stay compliant, it is all under one roof.

CLIENT RESULTS

Real mandates, real outcomes

01/07

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BTC Markets

Crypto Exchange

The first AFSL ever granted to a crypto exchange in Australia, backed by ongoing fixed-fee legal & compliance support.

THE OUTCOME

1st

AFSL for a crypto exchange in Australia

Retainer

Ongoing fixed-fee legal & compliance

AFSL APPLICATION • LEGAL • COMPLIANCE & REGULATION • RM RECRUITMENT

THE SITUATION

Australia’s leading crypto exchange needed legal and compliance expertise to navigate an ever-evolving crypto regulatory landscape, and wanted an AFSL to establish a payments business.

WHAT THEY NEEDED

Specialist legal and compliance expertise to stay ahead of fast-moving crypto regulation, and an AFSL to underpin a new payments business.

HOW WE HELPED

We secured the first AFSL ever granted to a crypto exchange in Australia, including the authorisations to support a payments business, and continue to act as an extension of their team under a fixed-fee retainer, providing dependable legal and compliance support as the landscape evolves.

Fixed fee · No obligation

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Damisa

Cross-Border Payments & Crypto Brokerage

AFSL secured to power cross-border payments using stablecoin rails, crypto buy & sell and multi-currency capabilities, giving customers same-day settlement and the ability to settle payments in cryptocurrency. 

THE OUTCOME

AFSL

Granted by ASIC

Stablecoins

Cross-border payments, crypto & multi-currency

AFSL APPLICATION · LEGAL · COMPLIANCE & REGULATION

THE SITUATION

A cross-border payment provider moving money in and out of Australia on behalf of customers using stablecoin rails, and wanting customers to be able to buy, sell and hold crypto and multiple currencies on its platform.

WHAT THEY NEEDED

A full-scope AFSL authorising cross-border payment services using stablecoins, the ability for customers to buy and sell crypto, and multi-currency capabilities.

HOW WE HELPED

We guided Damisa through a rigorous ASIC application and secured its AFSL, authorising cross-border payment services, enabling customers to buy and sell crypto, and providing multi-currency capabilities. We also assisted with AML registration as a remitter, ongoing legal and compliance set-up, PDS, FSG, TMD and T&Cs preparation, and support securing local banking and liquidity providers.

Fixed fee · No obligation

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Bless Payments

Payments & Remittance

A turn-key path to market, covering the full legal stack, an AFSL and AUSTRAC remittance registration.

THE OUTCOME

Turn-key

Legal, disclosure & licensing build

AFSL + AUSTRAC

Licence & remittance registration

AFSL APPLICATION • LEGAL • COMPLIANCE & REGULATION • RM RECRUITMENT

THE SITUATION

A payments and FX business preparing to come to market and needing its entire regulatory and legal foundation built from the ground up.

WHAT THEY NEEDED

Support across every element of operating a payments and FX business, including an AFSL, AUSTRAC registration and the full suite of legal documents.

HOW WE HELPED

We delivered a turn-key solution across their payments and FX business, preparing the legal documents and securing the AFSL and AUSTRAC remittance registration, and we continue to provide ongoing services today.

Fixed fee · No obligation

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Curated Capital

Wholesale Property Fund

Licensed to offer wholesale property syndicates, with ongoing legal and compliance support.

THE OUTCOME

AFSL

Granted for wholesale syndicates

Ongoing

Legal & compliance support

AFSL APPLICATION • LEGAL • COMPLIANCE & REGULATION

THE SITUATION

A wholesale property fund preparing to offer property syndicates to its clients.

WHAT THEY NEEDED

An AFSL and the disclosure documents required to offer wholesale property syndicates, plus ongoing legal and compliance support, including assistance administering each wholesale property syndicate.

HOW WE HELPED

We obtained their AFSL and established the disclosure documents required to offer wholesale property syndicates, and we provide ongoing legal and compliance support, including assistance administering each wholesale property syndicate.

Fixed fee · No obligation

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Hello Clever

Fintech & Payments

From an established business to a fully licensed, regulated product offering.

THE OUTCOME

Full-scope

AFSL secured

RMs placed

Responsible Managers sourced

AFSL APPLICATION • LEGAL • COMPLIANCE & REGULATION

THE SITUATION

An existing business looking to expand its product set into regulated financial offerings for the first time.

WHAT THEY NEEDED

To move through the AML registration phase, uplift its AML/CTF documentation and processes, and obtain a full-scope AFSL with the right Responsible Managers. 

HOW WE HELPED

We guided them through AML registration, updated their AML/CTF documentation and processes, sourced Responsible Managers and secured a full-scope AFSL, and now support them with their ongoing legal and compliance requirements on a fixed-fee retainer.

Fixed fee · No obligation

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Toss

Global Super-App

Korea’s leading financial SuperApp, now licensed to provide remittance services in Australia. 

THE OUTCOME

5 months

To a granted AFSL

End-to-end

Market entry & licensing

AFSL APPLICATION • LEGAL • COMPLIANCE & REGULATION • RM RECRUITMENT

THE SITUATION

Korea’s leading financial SuperApp seeking to establish a licensed remittance business in Australia.

WHAT THEY NEEDED

To establish a licensed remittance business in Australia, including a local presence and the licences and registrations required to provide domestic P2P payment services.

HOW WE HELPED

We stood up their Australian operations, covering incorporation, resident director, Responsible Manager, AFSL application and AML remittance registration, and secured the licence in five months. We now provide ongoing legal and compliance support.

Fixed fee · No obligation

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Immersve

Crypto Payments

Licensed, supported on an ongoing basis, and progressed toward Mastercard principal membership.

THE OUTCOME

AFSL

Granted & maintained

Mastercard

Principal membership work

AFSL APPLICATION • LEGAL • COMPLIANCE & REGULATION • RM RECRUITMENT

THE SITUATION

A global crypto-to-card payments business looking to establish operations in Australia and access card-scheme infrastructure.

WHAT THEY NEEDED

An AFSL, ongoing legal and regulatory support, and assistance securing Mastercard principal membership.

HOW WE HELPED

We obtained their AFSL and assisted them in accessing card-scheme infrastructure, including their Mastercard principal membership, at the outset. We now provide ongoing legal support, helping them navigate and comply with their local legal and regulatory requirements.

Fixed fee · No obligation

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Interstellar Capital

Wholesale Property Fund

AFSL secured and disclosure documents built for wholesale property syndicates.

THE OUTCOME

AFSL

Granted for wholesale syndicates

Ongoing

Legal & compliance support

AFSL APPLICATION • LEGAL • COMPLIANCE & REGULATION

THE SITUATION

A wholesale property fund bringing property syndicates to its investors.

WHAT THEY NEEDED

An AFSL and compliant disclosure documents for wholesale property syndicates, backed by ongoing legal and compliance support.

HOW WE HELPED

We obtained their AFSL and established the disclosure documents required to offer wholesale property syndicates, and we provide ongoing legal and compliance support.

Fixed fee · No obligation

TESTIMONIALS

Rated 5-star by our clients

Book your free, no-obligation consultation

Have a related, no-pressure chat with one of our senior AFSL lawyers. You’ll walk away knowing exactly where you stand and what to do next.

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Peter Hagias & team

WHY AFSL HOUSE

Why Choose AFSL House?

Our point of difference is simple: we specialise in working exclusively with financial services companies, offering solutions that combine best practice processes with full legal compliance.

Deep industry understanding

An intimate understanding of the issues financial services companies face, and how leaders in your industry address them.

Best practice + legal compliance

Solutions that marry best-practice processes with legally compliant strategies, so your business runs efficiently.

Broader perspective

We go beyond the narrow focus of traditional law firms or compliance providers to deliver holistic, practical solutions.

AFSL VIDEO SHORTS

AFSL, explained by our lawyers

Quick, plain-English answers to the questions we hear most, straight from the specialists who handle your licence.

Book your free, no-obligation consultation

Have a related, no-pressure chat with one of our senior AFSL lawyers. You’ll walk away knowing exactly where you stand and what to do next.

INSIGHTS LIBRARY

The latest news & insights

News, regulatory updates and analysis from our financial services lawyers, straight from the AFSL House desk.

Free 90-seconds Assessment

Not sure where you stand with your AFSL?

Answer a few quick questions and we’ll build you a personalised AFSL action plan, based on the very things ASIC will expect from you. It takes about 90 seconds. 

Question 1 of 4 AFSL Readiness Check

FREE DOWNLOADS

Free & practical AFSL guides & checklists

Practical guides, roadmaps and checklists that make getting ready simple, written by the lawyers who do this every day.

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GUIDE

2026 Guide to AFSL Applications

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ROADMAP

Your AFSL Roadmap

AFSL Compliance Checklist

CALENDAR

AFSL Compliance Calendar

THE DEAL

The critical role of Responsible Manager recruitment

The essential role of an RM

Securing or varying an AFSL requires demonstrating organisational competence to ASIC, making RM selection crucial. RMs provide the specific knowledge, skills and relevant experience essential to obtain or maintain a licence.

Good RMs are hard to find

ASIC requires recent, role-specific experience that aligns with your licence authorisations. We specialise in sourcing Responsible Managers who meet these strict standards, supporting your regulatory and commercial objectives from day one.

ASIC looks closely at RM experience

ASIC applies a strict, technical lens to RM competence; general financial services experience is not enough. Our legal team vets every RM to ensure they are fully compatible with your licence scope and authorisations.

APPOINTMENT & ONBOARDING

Supported from match to appointment, and beyond

Placing the right Responsible Manager is only the start. We manage the appointment process and support both parties so the relationship stands up to ASIC scrutiny long after onboarding.

Targeted to your authorisations

We assess your AFSL authorisations and business model in detail, then match RMs whose experience is directly relevant, recent and demonstrably compliant.

Legal due diligence you can trust

Every RM candidate is vetted by an AFSL lawyer, giving you confidence that your appointment supports both immediate needs and long-term compliance.

ASIC Form FS20 & engagement

We assist with ASIC Form FS20 notifications and engagement terms, ensuring the appointment is documented correctly and lodged on time.

Transition & ongoing support

We support all parties through transition and remain available as your licence and obligations evolve, keeping the RM relationship compliant.

Book your free, no-obligation consultation

Have a related, no-pressure chat with one of our senior AFSL lawyers. You’ll walk away knowing exactly where you stand and what to do next.

FAQ

Frequently asked questions

What is an AFSL Responsible Manager?

An AFSL Responsible Manager (RM) is an individual nominated by an Australian Financial Services Licence (AFSL) holder to demonstrate to ASIC that the licensee has the necessary knowledge, skills, and experience to provide the financial services authorised under its licence. They oversee financial service operations and ensure compliance, playing a vital role in the AFSL application and ongoing licence maintenance.

An AFSL holder must have at least one Responsible Manager. However, ASIC generally prefers two and may require more depending on the size, scale, and complexity of the financial service business and the range of financial products offered under the AFSL application. The aim is to adequately demonstrate organisational competence.

Key responsibilities include having direct responsibility for significant day-to-day decisions about the provision of financial services, supervising these services, ensuring the licensee complies with its AFSL obligations and the Corporations Act 2001 (Cth), and collectively with other RMs, demonstrating the licensee’s organisational competence to ASIC for all authorised financial products and services. This role is essential for maintaining the AFS licence.

The ‘fit and proper person’ test evaluates an individual’s character, integrity, and professional standing. It includes criminal history and bankruptcy checks (usually within the last 12 months) and requires at least two business references. ASIC assesses whether the person is likely to uphold the obligations of an AFSL honestly and fairly, which is a core component of the licence application process.

A person can be an AFSL Responsible Manager if they meet ASIC’s knowledge and skills requirements under one of the five options in ASIC’s Regulatory Guide 105, are a ‘fit and proper person’, and have direct responsibility for significant day-to-day decisions regarding the financial services offered under the AFS licence. They may be directors, employees, or contractors, but must always demonstrate competence for the licence.

Yes, a person can generally be a Responsible Manager for a maximum of two AFSL holders. ASIC imposes this limit to ensure the RM can dedicate sufficient time and attention to their responsibilities for each licensee and maintain compliance with all financial service obligations under each AFS licence. 

There are no single mandated qualifications, but ASIC outlines five options in RG 105 to demonstrate competence. These generally involve a combination of relevant tertiary qualifications (such as a university degree in business, commerce, economics, or finance), specific industry courses (like RG146 for retail client advice on financial products), and practical experience—typically three years in the last five or five years in the last eight—providing similar financial services or managing financial product operations under an AFS licence.

No, Responsible Managers do not have to be employees. They can be directors or contractors. However, ASIC scrutinises non-employee arrangements to ensure the RM has genuine direct responsibility and involvement in the financial service operations and is not merely an “RM for hire” without real oversight for the AFSL. 

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2026 Guide to
AFSL Applications

Ready to apply for an AFSL? Download our practical step-by-step guide to securing your AFSL from ASIC.

Get insider insights on ASIC’s new licensing portal, application trends, approval timelines, and practical steps to fast-track your AFSL application in 2025.

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