ADI Licensing Solutions for Australian Authorised Deposit Takers | Pre-licensing Assessment | ADI Application Management | Post-licensing Risk and Compliance Support

We offer a comprehensive set of solutions to help you obtain and maintain an Australian Authorised Deposit-taking Institution authorisation (commonly referred to as the ADI licence) issued by the Australian Prudential Regulation Authority (APRA), tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technological resources
• Your risk appetite
• Your governance structure
• The products that you offer
• Australian ADIs' obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our regulatory licensing solutions to help you navigate the complexities of the authorised deposit-taking institution licensing regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the Authorised Deposit-taking Institution licensing process, including but not limited to the following aspects:

• ADI Licence Guidance: Advising on a wide range of aspects associated with ADI licence as it relates to your specific situation
• Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
• Pre-licensing support:
• Drafting the necessary policies and procedures to help you comply with the authorised deposit-taking institution licensing conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the authorised deposit-taking institution licensing regime
• Australian ADI Licence Application Support: Covering the entire licensing process
• Post-licensing Support: Covering
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• AML/CFT advice
• AML/CFT compliance management
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

Service Coverage

This page is about Australian Authorised Deposit-taking Institution (ADI) licensing. Under the Banking Act 1959, entities conducting banking business in Australia must hold an ADI licence issued by the Australian Prudential Regulation Authority (APRA). This licence authorises deposit-taking activities and imposes ongoing prudential, governance, and compliance obligations. Depending on the business model, additional requirements may apply (e.g., Australian Financial Services Licence (AFSL) for certain activities, AUSTRAC registration for AML/CTF compliance). We offer support for Australian ADI licence applications tailored to:

• Retail ADIs
• Wholesale ADIs
• Mixed-Model ADIs
• Foreign ADIs expanding into Australia
• Financial Institutions integrating deposit-taking activities

You can find more information about our Australian ADI licensing solutions below:

 

Australian ADI Licence Preparation

Pre-licensing Compliance Assurance

Our ADI licence solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for an ADI licence
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the Authorised ADI licensing process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your ADI licence, tailored to suit your:

• business objectives,
• operational capacity,
• client base,
• markets of operations,
• and other relevant factors

• Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
• Australian ADI Licence Application Plan: We help you establish a roadmap to effectively meet the requirements for your ADI licence

 

 

ADI Licence Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our authorised deposit-taking institution licensing solution covers:

• Compliance Model Selection: To help you best comply with the authorised deposit-taking institution licensing regime and related risk and compliance obligations.
• Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
• Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the licensing requirements for deposit takes and lenders and other applicable regulated Australian ADIs' obligations, keeping in mind your specific circumstances, available resources and business goals.

 

ADI Licence and Entering a Regulated Environment

We help businesses transition from an unregulated environment to operating under the authorised deposit-taking institution licensing regime, helping them meet their obligations as a ADI licence holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the authorised deposit-taking institution licensing regime requirements.

Our focus areas for this service include:

• New businesses
• Existing ADIs operating in unregulated markets
• Regulated ADIs that expand into foreign jurisdictions
• Financial institutions and/or service providers with established risk and compliance frameworks seeking to offer regulated deposit-taking or lending services as a new product.

 

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with regulated deposit-takers' obligations globally.

 

ADI Licence and Wholesale Markets

Getting an ADI licence may not always be the best fit for all. For example, a retail market expansion may not always align with your goals or the products you offer.

Operating in the wholesale environment can sometimes be a more suitable option. We offer a wider range of risk and compliance management solutions to assist ADIs that:

• Operate in the wholesale markets
• Operate under exemptions from the authorised deposit-taking institution licensing regime
• Operate under an ADI licence limited to sophisticated, eligible, and wholesale investors

We help these businesses comply with the regulatory compliance obligations that still apply despite the absence of the authorised deposit-taking institution licensing regime or apply under the wholesale-only licensing framework, including:

• Advertisement Rules
• Fair Dealing Regulations
• Risk Management
• Outsourced Providers' Oversight
• Restrictions on offering services to retail investors (an integral part of the authorised deposit-taking institution licensing regime)
• Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) laws and regulations
• Data Management Laws and Regulations

 

Australian ADI Licence Application

We assist with your licence application through ongoing engagement in the Authorised deposit-taking institution licensing process:

• Document Compilation and Review: We compile and review all required supporting documents to support your Australian ADI licence application.
• Application Form Completion: We assist you in completing the forms to ensure all material information is accurate and complete.
• Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Australian ADI Licensing Process and Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the licensing process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving ADI Licence Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our ADI licence solutions include a range of services to address and resolve these issues effectively:

• Remediation Solutions for ADI Licence Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with the authorised deposit-taking institution licensing regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your ADI licence, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.

• Licensing Issues Handling: We address common licensing issues encountered during the Australian ADI licensing process, providing you with solutions to navigate and resolve these challenges efficiently.
• Further Information: You can visit our Compliance Remediation Solutions page for more information.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for licensed ADIs. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• Regulated Australian ADI's Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the authorised deposit-taking institution licensing regime and other regulatory compliance obligations. For more information, please visit our Compliance Consultancy Service page.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our Specialised Compliance Management Solutions page for ADIs.
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:
• Regulated Australian ADIs’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• Australian ADIs’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.
• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for Australian ADIs. For more information, visit our Specialised AML/CFT Solutions page for ADIs.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (e.g., your banking partners, insurance companies, and liquidity providers).

 

 

Risk and Compliance Obligations for ADI Licence Holders

ADI licence holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support across various areas. The list below is not exhaustive:

ADI Licence and Regulatory Compliance Obligations

• Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more (as per the requirements of the Banking Act 1959 s 13A and APRA Prudential Standard CPS 220 Risk Management, CPS 510 Governance, CPS 520 Fit & Proper).
• Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil regulated Australian ADI obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks (as per APRA Prudential Standard CPS 220 Risk Management).
• Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the Australian ADI licensing requirements.
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the Australian ADI licensing regime.
• Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
• Capital Adequacy Requirements: We assist Australian ADIs in developing capital adequacy monitoring controls where required under licensing frameworks, including credit unions, building societies, and non-bank lenders operating under prudential or financial licensing regimes.
• Liquidity Management Requirements: We help implement liquidity monitoring and cash flow stress testing controls for licensed Australian ADIs, particularly where operating under financial institution or protected deposit frameworks.
• Financial Auditing Standards: We can assist in establishing procedures to help you comply with the audit and assurance requirements under the Australian ADI licensing regime.

 

ADI Licence and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with Authorised deposit-taking institutions' licensing obligations for overseeing outsourced services (as per the requirements of APRA Prudential Standard CPS 231 Outsourcing and CPS 220 Risk Management), also covering related obligations under AML/CFT compliance, ISO requirements, and more.
• Structures for Governance: We can help you establish effective governance structures to comply with Australian ADIs’ obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
• Senior Management Accountability: We can help you comply with Australian ADIs’ obligations for senior management and key staff conduct and competence.
• Maintaining Operational Resilience: We assist in developing continuity plans to meet Australian ADIs’ obligations for operational resilience, helping critical business services withstand disruptions.
• Managing Technology Risks: We provide guidance on technology risk management obligations under the Australian ADI licensing regime.
• Board Risk Appetite Statement: We assist Australian ADIs in developing formal Board-approved Risk Appetite Statements, supported by internal risk limits, board reporting thresholds and escalation frameworks in line with CPS 220 obligations (as per the requirements of APRA Prudential Standard CPS 220)
• Business Continuity and Contingency Planning: We help Australian ADIs implement business continuity and disruption response frameworks aligned to APRA CPS 230, including service mapping, impact tolerances, and operational resilience strategies (as per the requirements of APRA Prudential Standard CPS 230).

 

ADI Licence and Market Integrity/Transparency Requirements

• Standards for Market Conduct: We can help you implement controls for Australian ADIs’ obligations to maintain fair and transparent market conduct, including preventing manipulation and insider trading (as per the requirements of Corporations Act 2001 Pt 7.8 and ASIC Regulatory Guides 168, 175 and 271).
• Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients.
• Standards for Conduct and Disclosure: We can help you comply with Australian ADIs’ licensing standards for conduct and disclosure.
• Product Suitability and Governance: We can establish tailored controls to help licensed ADIs comply with product suitability and governance obligations, including risk management and governance arrangements across the product life cycle (as per the requirements of ASIC Regulatory Guide 274 Product Design and Distribution Obligations).
• Protection of Client Assets: We can help you comply with Australian ADIs’ licensing obligations to protect and segregate client assets.
• Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients.

 

ADI Licence and Resource Management Obligations

We can help you comply with the following requirements of the Australian ADI licensing regime:

• Adequacy of Resources: Covering financial, technological, human and other resources.
• Competence of Professionals: Covering key personnel, their necessary skills, knowledge, and professional competence.
• Our focus areas include:

• Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the licensing regime.
• Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
• Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
• Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
• Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, deposit taking or lending regulations.
• Competence and Accreditations of Advisors and Representatives: We can advise you on certifications and continuing professional development (CPD) requirements for compliance professionals and senior management.
• Representative Vetting: We can help establish a framework for assessing the competence and suitability of advisors and representatives before appointment.
• Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
• Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.
• Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.

 

ADI Licence and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • Australian ADIs’ licensing obligations
  • Australian ADIs’ AML/CFT obligations (SMRs, STRs, SARs, cross-border transaction reports, cash transaction reports, and other reporting obligations)
  • Australian ADIs’ obligations under financial market conduct regulations
• Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
• Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the Australian ADI licensing regime, applicable operational standards, and more.

 

Related Licensing Solutions

We can help you apply for the derivatives issuer's AFSL or its equivalents in the following jurisdictions:

• New Zealand: For more information on the New Zealand equivalent of the derivatives issuers' AFSL – Derivatives Issuer’s FMA Licence, as well as Financial Service Provider (FSP) registration for non-retail derivatives offerings, you can visit our New Zealand Derivatives Issuer’s Licence page.
• United Kingdom: For more information on the United Kingdom derivatives issuers' AFSL equivalent – FCA Authorisation for Regulated Derivatives Activities, you can visit our FCA Authorisation page.
• Singapore: For more information on the Singaporean derivatives issuers' AFSL equivalent – Capital Markets Services (CMS) Licence for dealing in derivatives contracts, you can visit our Capital Markets Services (CMS) Licence page.
• Other Jurisdictions: We also offer derivatives issuers’ licensing solutions for prominent financial centres and offshore tax havens, including but not limited to:

• British Virgin Islands: Where licensed derivatives issuers are supervised under the Securities and Investment Business Act, 2010 (SIBA) by the British Virgin Islands Financial Services Commission (BVI FSC).
• Cayman Islands: Where derivatives activity is regulated under the Securities Investment Business Act (2020 Revision) by the Cayman Islands Monetary Authority (CIMA).
• Seychelles: Where derivatives issuers are licensed under the Securities Act, 2007, by the Seychelles Financial Services Authority (FSA).
• Mauritius: Where derivatives dealers are licensed under the Securities Act 2005 by the Mauritius Financial Services Commission (FSC).

 

Related Services

We assist in obtaining ADI licence equivalents in the following jurisdictions:

• United Kingdom: For more information on the UK equivalent of an ADI licence, the UK building society authorisation, you can visit our UK Building Society Authorisation page.
• New Zealand: For more information on the New Zealand equivalent of an ADI licence, you can visit our Deposit Takers Licence page.
• United States: For more information on the United States equivalent of an ADI licence, the Federal Savings and Loan Association license, you can visit our Federal Savings and Loan Association Licence page.
• Singapore: For more information on the Singaporean equivalent of a Federal Savings and Loan Association license, the finance company licence, you can visit our Singapore Finance Company Licence page.
• Other Jurisdictions: We also offer licensing solutions for finance company licensing in prominent financial centres and offshore tax havens, including but not limited to: