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Lawyers for discretionary mutual funds

Structure your discretionary mutual fund with clear regulatory & structuring advice for member-based protection outside the insurance framework.

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Trusted by industry leaders

300+ AFSL holders · excellent on Google

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Licensing Discretionary Mutual Funds

HOW WE DO IT

Structure your DMF with clear regulatory advice & compliance

We advise discretionary mutual funds on structuring, regulatory characterisation, member documentation & ongoing governance so they can operate with confidence. 

BY THE NUMBERS

Discretionary mutual funds, by the numbers

SERVICE LINE

Discretionary Mutual Funds

Regulatory & structuring advice, member documentation, governance & AML/CTF support for discretionary mutual funds (DMFs).

Fund AFSLs obtained

0 +

Application success rate

0 %

INDUSTRIES WE SERVE

Property Funds
Equity Funds
Alternative Funds
Discretionary Mutual Funds
Investment Managers
Responsible Entities
VC & Private Equity

HOW IT WORKS

From licence to ongoing compliance

From licence to ongoing compliance

Two clear tracks: first we get you licensed and registered, then we keep you compliant as you scale.

Two clear tracks: first we get you licensed and registered, then we keep you compliant as you scale.

1

Discovery & regulatory characterisation

We confirm how your fund is characterised, that it sits outside the insurance and APRA framework, and which AFSL authorisations are engaged.

2

Structuring & licensing strategy

We structure the fund and map your AFSL pathway with ASIC, plus AUSTRAC registration where AML/CTF obligations apply.

3

Member documentation & lodgement

We draft your fund rules, member documentation and disclosure, then prepare and lodge your AFSL application with ASIC.

4

Authorisation & launch

We manage ASIC queries through to authorisation, so you launch licensed and ready.

1

Governance & conduct framework

We build your governance, compliance and AML/CTF frameworks so obligations are workable from day one.

2

Monitoring & reviews

We run periodic compliance reviews and monitoring so issues surface early, not at audit.

3

Reporting & breach management

We support regulatory reporting, breach reporting and ASIC correspondence as they arise.

4

Ongoing advisory

We act as an extension of your team, variations, new arrangements and regulator engagement as you grow.

WHAT WE DO

Specialist licensing & compliance for funds & investment managers

We advise fund managers across structuring, licensing, disclosure & day-to-day compliance.

Regulatory Perimeter & Licensing Advice

We advise whether your fund or investment business requires an AFSL & which authorisations suit your structure & clients.

AFSL Applications & Variations

We prepare licence applications & variations, including the dealing, advice & scheme-operator authorisations fund managers commonly need.

Fund Structuring & Constitutions

We structure wholesale & retail funds & draft constitutions, trust deeds & scheme documents that fit your strategy & investors.

PDSs, IMs & Target Market Determinations

We draft or refine Product Disclosure Statements, Information Memoranda & TMDs that meet disclosure & DDO obligations.

Compliance Plans, Custody & Governance

We design compliance plans, custody arrangements & governance frameworks that meet ASIC’s expectations for managed funds.

AML/CTF & AUSTRAC Programs

We develop AML/CTF programs & advise on AUSTRAC obligations tailored to fund & investment management activity.

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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 for your fund?

We understand how fund & investment managers operate, from structuring & capital raising to compliance & investor protection.

Funds & investment expertise

We understand how fund & investment managers operate, from structuring & capital raising to compliance & investor protection.

Integrated licensing & compliance

We align licensing strategy, fund structuring, PDSs/IMs & TMDs, compliance plans & AML/CTF programs into one coherent framework. 

Commercially practical advice

We explain regulatory constraints & help you protect your strategy, returns & investor relationships: practical options, not red-flag lists.

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

MORE IN THIS SECTOR

Explore banking & fintech licensing

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 a discretionary mutual fund (DMF)?

A DMF is a member-based arrangement that provides discretionary protection against agreed risks, operating outside the traditional insurance framework. We advise on how a DMF is characterised and what regulatory perimeter applies.

It depends on the structure and what is offered. Some DMF arrangements engage the AFSL or other regimes; others sit outside them. We assess your model and advise precisely what authorisations, if any, are required.

A DMF provides discretionary (not contractual) protection and is member-owned, which changes its regulatory treatment. We help structure the arrangement so this distinction is clear and defensible.

Typically member rules, a discretionary protection document, governance and capital policies, and an AML/CTF program where relevant. We draft or refine each for your DMF.
Yes. We support DMFs on a retainer: governance, member documentation, regulatory monitoring and ongoing advice as the fund grows.

100% Free Download

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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