In November 2025, ASIC commenced Federal Court proceedings against Interprac Financial Planning (“Interprac”), alleging serious failures in supervision, product governance and risk management connected to the Shield and First Guardian investment schemes. Interprac is not a small or marginal licensee. It has operated since 2004 and forms part of Sequoia Financial Group, one of Australia’s larger diversified financial services businesses. According to ASIC’s concise statement, the relevant Interprac-authorised advisers provided advice to more than 6,800 retail clients, with over $677 million invested in the Shield and First Guardian Master Funds. The size of the client base and the volume of funds involved illustrate why ASIC views the alleged failures not as isolated issues, but as systemic supervisory failures resulting in widespread client harm that warrant significant court-based intervention.
ASIC’s media releases (25‑274MR (Interprac) and 25‑275MR (SQM Research)) set out claims that Interprac failed to identify behavioural patterns, unusual product flows and adviser-driven risks, issues ASIC argues a modern licensee should detect early. These proceedings will continue well into 2026, but the direction of travel is already clear: ASIC expects licensees and Responsible Managers to be organised, data-enabled and able to demonstrate that their supervision works in practice, not just on paper.
Why is the Interprac case a warning shot for every Licensee?
We think that ASIC’s 2025 Federal Court proceeding against Interprac may be one of the most consequential licensee‑supervision cases since Lanterne and RI Advice. But unlike those cases, where failures centred on governance or cybersecurity, the Interprac matter goes to the core operational DNA of a licensee: its ability to detect patterns of misconduct, product concentration and systemic advice failures before they cause client detriment.
This isn’t simply an “Interprac problem.” ASIC has made it clear that Licensees are responsible for detecting emerging risks, behavioural patterns and problematic advice trends across their network and acting early.
The alleged failures at Interprac expose the limitations of siloed, analogue, unscalable supervision approaches.
ASIC has repeatedly emphasised in recent speeches that effective oversight now depends on licensees using systems and data to identify emerging risks early and to demonstrate that their supervision is active, not symbolic.
Do your systems detect emerging risks, behavioural patterns, product concentration and systemic advice issues before they crystallise into harm?
The alleged failures at Interprac expose the limits of siloed reviews, spreadsheet monitoring and reactive supervision frameworks.
In our view, the case shows why licensees now need real-time, data-driven, RegTech-enabled supervision to meet their obligations under s912A, RG104 and RG105. RG 104 and RG 105 emphasise systems that are appropriate, adequate and effective for the business’ nature, scale and complexity.
The point ASIC is making is unmistakable:
Licensees must identify patterns — not just file-by-file errors.
Systems must work in practice — not just exist on paper.
And critically that manual supervision, sparse file reviews and spreadsheet-based oversight can’t meet that standard in modern advice businesses.
What are the alleged failures?
Based on ASIC’s media release (25-274MR) and the Concise Statement filed in the Federal Court, ASIC alleges Interprac breached several key obligations under s912A of the Corporations Act.
In particular, ASIC says Interprac failed to supervise its advisers effectively, failed to maintain adequate risk-management systems, and failed to ensure financial services were provided efficiently, honestly and fairly.
How did Interprac fail to supervise and monitor advisers (s912A(1)(ca))?
ASIC’s concise statement focuses heavily on the conduct of two authorised representatives — Venture Egg and RRPL — who advised thousands of clients into the same small cluster of high-risk investment products. Together, these representatives accounted for approximately $677 million in client funds directed into Shield and First Guardian, raising clear questions about product concentration, adviser conduct and the adequacy of Interprac’s oversight of these entities.
In addition, ASIC alleges that advisers routinely recommended 100% allocations to products with no track record, limited transparency, and red flags that should have triggered heightened monitoring.
ASIC alleges Interprac failed to detect and respond to:
- Massive flows of client funds into the Shield and First Guardian investment schemes
- Significant reliance on third-party lead generators
- Serious compliance issues repeatedly identified in audit findings
- Negative-consent practices that resulted in clients being moved into high-risk products without express consent
These are indicators of behavioural and systemic patterns, not isolated advice errors.
How were Interprac’s risk management systems inadequate (s912A(1)(h))?
ASIC alleges Interprac:
- Lacked a robust product-approval process, relying almost entirely on external research to add Shield and First Guardian to its APL
- Failed to respond appropriately to red flags, including:
- significant inflows into the funds
- concerns identified by its own responsible manager
- information about payments to companies connected to individuals of concern
- Did not maintain an effective hold on new investments once issues were recognised
ASIC further alleges that Interprac placed the funds on “hold” after internal concerns were raised, but did not enforce that restriction in practice. Advisers continued recommending the products, and clients continued being switched into them.
ASIC also claims that Interprac’s review processes focused on the form of advice documents rather than on whether the products themselves were suitable. This structural oversight contributed to systemic risk.
These are failures of system capability, not simply staff behaviour.
Interprac’s systems may have existed on paper, but ASIC argues they didn’t work in practice.
How did Interprac fail to ensure advice was efficient, honest and fair (s912A(1)(a))?
ASIC alleges Interprac’s inadequate supervision led to:
- tens of hundreds of clients being advised into high-risk, unsuitable products
- serious consumer harm that effective systems might have prevented
- repeated use of template complaint responses that did not assess the appropriateness of advice
ASIC describes these issues as systemic rather than incidental. The concise statement points to repeated patterns of templated advice, unrealistic assumptions in modelling, and the influence of external lead-generation businesses that funnelled clients toward a predetermined product outcome.
These characteristics, ASIC argues, should have been visible to any licensee with effective supervision systems.
In fact, this reinforces ASIC’s long-held position that Licensees are responsible not only for adviser conduct, but also for the systems and controls that prevent foreseeable harm.
Even if individual advisers were the immediate cause of harm, ASIC alleges the licensee should have detected the patterns and intervened. Failure to act became failure to supervise—and ultimately a failure to meet core financial services obligations.
How does the Interprac case highlight the limits of manual compliance?
Most licensees still rely on:
- sample-based file reviews
- spreadsheet-driven monitoring programs
- manual breach detection
- adviser self-reporting
- isolated CRM data
- compliance audits performed episodically
ASIC’s concise statement highlights several situations in which Interprac’s episodic review processes failed to detect obvious patterns: identical Statements of Advice issued to unrelated clients, unusually high product flows inconsistent with client objectives, and repeated adviser behaviour that should have triggered an escalation. These examples reflect the inherent limitations of analogue, disconnected supervision approaches that cannot be interrogated or scaled.
Specifically, Interprac illustrates three fundamental problems with this approach:
1. Manual systems cannot detect patterns
Product clustering, unusual inflows, repeated narratives, and systemic advice issues only emerge when data is aggregated and analysed continuously.
2. Manual systems cannot scale
No compliance team — no matter how capable — can manually monitor the behaviour of dozens or hundreds of advisers across thousands of clients and millions of dollars in flows.
3. Manual systems cannot provide early warning
By the time a problem shows up in a file review, the harm has usually occurred.
This is the gap ASIC is now targeting.
What does the Interprac case mean for Licensees right now?
The Interprac case signals that ASIC expects licensees to:
- Move beyond sample-based reviews to whole-of-licensee surveillance
- Detect patterns of product flows and adviser behaviour
- Identify issues early, before harm crystallises
- Demonstrate that systems and controls are operationally effective, not symbolic
- Provide evidence that Responsible Managers satisfy RG 105 (organisational competence) and RG 104 (general obligations) expectations.
ASIC expects effective, data-enabled oversight proportionate to the business’ nature, scale and complexity, consistent with s912A and RG 104 and 105; it is an expectation of effective, data-enabled oversight proportional to the nature, scale and complexity of the licensee’s business.
Manual audits, CRM exports and human-led reviews can’t achieve this. Instead, Licensees now need technology with analytical power, integrated workflows and real-time visibility.
Commissioner Hayne’s view was clear: “Licensees breach s912A not only by misconduct, but when they fail to organise and resource themselves to prevent foreseeable harm.”
Interprac is a case study in that principle.
ASIC’s parallel proceeding against SQM Research — alleging that the research house failed to obtain adequate information about Shield, did not investigate inconsistencies, and issued a favourable rating without reasonable grounds — reinforces that responsibility extends beyond licensees.
The message is clear: when product failures occur, ASIC will examine not just the advisers, but every gatekeeper whose conduct contributed to consumer harm. This “whole-of-market” posture represents ASIC’s broader shift toward systemic accountability.
To understand the broader implications, it’s worth asking: What does the Interprac case tell us about the future of compliance and supervision? And, equally, how can RegTech help licensees avoid the failures ASIC identified?
The future of compliance isn’t about bigger checklists or more manual reviews. It’s about integrated monitoring, behavioural analytics and system-level visibility. Licensees need to see, understand and respond to adviser behaviour as it happens. RegTech answers exactly this need.
By aggregating data, identifying patterns and automating escalation pathways, platforms like [complye] help licensees spot issues early before ASIC, AFCA, or clients do.
How can technology help licensees meet this standard?
Technology helps licensees meet this standard by providing consistent, structured and repeatable monitoring that manual methods can’t deliver at scale. Rather than promising automatic or continuous surveillance, RegTech strengthens a licensee’s ability to analyse data, recognise patterns, maintain oversight, and generate integrated reporting that supports timely, well-informed decisions.
The real advantage is reliability: technology ensures consistent monitoring, insights are easier to spot and act on, and supervision activity is properly documented.
RegTech enhances compliance teams’ capabilities, it doesn’t replace their judgement.
Tools like [complye] give licensees the systems and workflow structure needed to identify emerging issues sooner, coordinate responses, and demonstrate to ASIC that their oversight is active, evidence-based, and effective.
This is why adopting a platform like [complye] is the difference between being nominally compliant and proving it in practice.
Platforms like [complye] help Licensees to:
✔ Detect patterns and emerging risks
Including abnormal flows, clustering, behavioural anomalies and repeated narratives.
✔ Integrate monitoring, breach management and remediation
Providing clear escalation pathways and auditable records.
✔ Centralise records and compliance activity
Supporting obligations under s912A(1)(a), (ca), (e) and (h).
✔ Provide dashboard visibility for Responsible Managers
Helps RMs demonstrate ongoing competence under RG105, backed by real evidence.
✔ Document supervision activity
Providing ASIC with evidence that systems are active and effective.
✔ Reduce blind spots
Giving compliance teams the visibility they need to intervene early.
✔ Consistency and defensibility
Reduces human bias and inconsistency, strengthening defensibility during ASIC surveillance or enforcement.
In short, [complye] operationalises the obligations licensees already carry and provides the system-level capability ASIC expects.
How should Licensees respond to ASIC’s actions against Interprac?
In light of ASIC’s action against Interprac, licensees should:
- Evaluate whether their systems can detect behavioural patterns and risk clusters.
- Assess whether manual supervision processes create blind spots.
- Map capabilities against s912A and RG104/RG105 with real evidence.
- Adopt technology that provides whole-of-licensee monitoring.
- Focus on preventing harm, not retroactively detecting it.
The goal isn’t simply avoiding enforcement; it’s building a modern, efficient, data-driven licensee that can demonstrate genuine competence, provide evidence-based oversight, anticipate risks before they crystallise, and show ASIC that its systems don’t just exist on paper, they work in practice to prevent consumer harm.
Modern supervision requires modern systems.
Is Interprac an outlier or a regulatory signal?
ASIC proceedings against Interprac aren’t an escalation of regulatory responses nor an isolated incident with limited applicability; while the degree of the alleged failures may not be universal, the regulatory expectations are. For Licensee Management and Responsible Managers, it’s a clear and immediate signal about what ASIC expects from a modern AFS licensee. It’s not an “exception” but a regulatory marker of expected conduct and a clear signal that:
- Oversight must be proactive, structured and evidence-based
- Systems must be appropriate, adequate and effective
- Compliance functions must be genuinely operational, not symbolic
- Technology is increasingly essential to deliver the level of insight ASIC now expects
Or as ASIC Chair Joe Longo has often emphasised, compliance must be “effective in practice,” not just set out in policy documents.
And crucially, as ASIC has repeatedly stated in RG 104 and RG 105, licensees must have systems, controls and resources that are “appropriate, adequate and effective” for the nature, scale and complexity of their business. Technology now forms a critical part of meeting that standard, because it enables the structured monitoring, record‑keeping and evidence ASIC expects from a modern AFS licensee. As ASIC Chair Joe Longo has emphasised in multiple speeches since 2022, the regulator expects licensees to use data, systems and technology to identify emerging risks early, strengthen oversight and demonstrate that compliance functions are “effective, not symbolic” in practice.
Manual systems cannot meet that expectation. Modern RegTech, like [complye], can.
Licensees that invest early will be better positioned to satisfy ASIC’s expectations, demonstrate real oversight and operate with the confidence that their compliance framework is both defensible and future-ready.
Those who delay will continue to carry blind spots, operational risk and regulatory uncertainty that are no longer acceptable. If you’d rather be the former than the latter, reach out to us to see why leading licensees have embraced [complye].
To learn more about [complye], contact us today.
If you enjoyed this article, you might also like:
- Ethics at the Edge
- Systemic and Recurring Failures in Scaled Advice Businesses
- Deploying [complye]: A Practical Framework For Successful Adoption
Frequently Asked Questions
Venture Egg Pty Ltd and Rhys Reilly Ptd Ltd were authorised representatives of Interprac, whose advisers recommended Shield and First Guardian to thousands of clients. According to ASIC’s concise statement, clients of these representatives collectively invested more than $667 million into the two schemes; a concentration of flows that ASIC argues Interprac should have identified and investigated much earlier.
ASIC alleges Interprac breached s912A by failing to supervise advisers, govern products and manage risks tied to the Shield and First Guardian schemes, including not detecting abnormal flows or behavioural patterns.
Manual, sample-based file checks rarely reveal clustering, unusual flows or templated advice at scale. ASIC expects pattern detection across the licence, supported by data, escalation workflows and auditability.
RG 104 sets expectations for meeting s912A general obligations; RG 105 covers organisational competence (including Responsible Managers). ASIC’s case underscores that systems must be appropriate, adequate and effective, and demonstrably operational.
On the same day, ASIC sued SQM Research, alleging misleading research reports (25-275MR). ASIC also pursued freezing and winding-up orders linked to First Guardian earlier in 2025, evidencing a whole-of-market posture.
Map controls to s912A and RG 104/105; implement data-enabled surveillance; evidence RM oversight; integrate breach/remediation workflows; and document outcomes to prove systems work in practice.
