Rated excellent on Google
Lawyers for non-coded loans
Structure your business & non-coded lending with clear regulatory & structuring advice outside the NCCP Act.
- Perimeter advice for non-NCCP credit
- Structuring outside the NCCP Act
- Business loan & facility documents drafted for you
- Governance, risk & AML/CTF programs
FREE · NO OBLIGATION · QUICK REPLY
Book a free consultation
Confidential. We never share your details.
Trusted by industry leaders
300+ AFSL holders · excellent on Google
HOW WE DO IT
Structure non-coded lending with clear regulatory advice
We advise on business loans and other credit that falls outside the NCCP Act, structuring and documenting your facilities to fit.
BY THE NUMBERS
Non-coded loans, by the numbers
SERVICE LINE
Non-Coded Loans
Regulatory & structuring advice, facility documents & compliance for business loans & other non-coded credit.
Non-coded structures advised
Facility & loan documents drafted
INDUSTRIES WE SERVE
Lenders
Finance Brokers
Credit Funds
Non-Coded Loans
BNPL
HOW IT WORKS
From first facility to ongoing compliance
From first facility to ongoing compliance
Two clear tracks: first we get your documents, AUSTRAC enrolment and frameworks in place, then we keep them current as you scale.
Two clear tracks: first we get your documents, AUSTRAC enrolment and frameworks in place, then we keep them current as you scale.
1
Perimeter review
We confirm your lending sits outside the NCCP Act, so no credit licence is required, and flag anything that would pull you back into the regime.
2
Loan document preparation
We draft your loan agreements, guarantees, security documents and disclosure pack so each facility holds up commercially and legally.
3
AUSTRAC enrolment & AML program
Where your lending is a designated service, we enrol you with AUSTRAC and build the AML/CTF program, KYC and reporting processes behind it.
4
Frameworks & launch
We put your credit, conduct and privacy frameworks in place and hand over templates and process maps so you can start lending.
1
Document & framework refresh
We keep loan documents and policies current as your products, security positions and the law change.
2
AUSTRAC obligations
We support ongoing AML/CTF duties: independent reviews, transaction and suspicious matter reporting, and annual compliance reports.
3
File reviews & monitoring
We run periodic file and process reviews so gaps in execution surface early, not in a dispute.
4
Ongoing advisory
We act as an extension of your team on new facilities, borrower disputes and regulator engagement as you grow.
WHAT WE COVER
What we cover for non-coded lending
We help private, business and wholesale lenders document facilities, meet AUSTRAC duties and keep frameworks current, without a credit licence.
Regulatory Perimeter Review
We confirm your lending sits outside the NCCP Act, and flag the terms or borrower types that would pull you into it.
Loan & Security Documents
We draft loan agreements, guarantees, mortgages and general security deeds tailored to each facility.
Term Sheets & Borrower Packs
We build the term sheets, disclosures and onboarding packs your borrowers sign, consistent across every deal.
AUSTRAC Enrolment & AML/CTF
We enrol you with AUSTRAC where required and build the AML/CTF program, KYC and reporting behind it.
Credit & Governance Frameworks
We set up credit assessment, conduct, privacy and record-keeping frameworks, then review files periodically.
Recovery & Enforcement
We advise on default, demand and enforcement of security when a borrower stops performing.
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
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
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
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
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
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
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
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
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.
Peter Hagias & team
WHY AFSL HOUSE
Why choose AFSL House for non-coded lending?
Private, business and wholesale lending sits outside the credit regime, but not outside scrutiny. We make sure your documents, AUSTRAC position and frameworks hold up.
Perimeter certainty
We know exactly where the NCCP line sits, so you lend without a credit licence and without the risk of drifting into the regime.
Documents built to be enforced
Loan agreements, guarantees and security documents drafted so they stand up if a borrower defaults, not just at signing.
AUSTRAC & frameworks handled
Enrolment, AML/CTF programs, credit and privacy frameworks set up and kept current, so compliance runs in the background.
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
Lending & credit insights
Stay ahead of evolving regulation with free guides, checklists & insights on lending & credit licensing, written by our specialist AFSL lawyers.
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.
- Takes under 2 minutes
- Tailored to your business type
- No cost, no obligation
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.
MORE IN THIS SECTOR
Explore lending & credit 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.
WHY WE DO
Market-leading, comprehensive AFSL services
A comprehensive range of services tailored to financial services companies seeking an Australian Financial Services Licence and ongoing compliance support.
AFSL Applications
A 100% success rate in AFSL applications, helping clients obtain their licence in record time.
ACL Applications
End-to-end Australian Credit Licence applications for lenders, brokers and credit providers, prepared and lodged for you.
Compliance & Regulation
Tailored risk and compliance frameworks to ensure you comply with your AFSL obligations.
Legal Support
Specialised AFSL lawyers providing holistic legal services to AFSL holders & applicants.
AFSL Audits & Investigations
Comprehensive governance audits to avoid enforcement action and assist in ASIC & AUSTRAC investigations.
AFSL for Hire
Be appointed as a Corporate Authorised Representative under our AFSL to start operating quickly.
Marketplace for AFSL
Connecting AFSL holders and applicants with qualified Responsible Managers, with expert sourcing and placement handled for you.
AFSL Responsible Manager Recruitment
Connecting AFSL holders and applicants with qualified Responsible Managers. Expert RM sourcing and placement.
White-Label Services
Enabling legal and consulting firms to offer AFSL expertise under their own brand.
FAQ
Frequently asked questions
What is non-coded credit?
Do I need an ACL for business lending?
What documents do I need?
Loan and facility agreements, security documents and disclosure appropriate to your borrowers, plus an AML/CTF program where relevant. We draft these for you.
Do you provide ongoing support?
Yes. We support non-coded lenders on a retainer: structuring, documentation and regulatory monitoring as your products evolve.