Compliance Plans in Practice
Compliance plans are more than a regulatory requirement — they are the foundation of accountability and resilience in fund operations. They set expectations, allocate responsibility, and demonstrate to both investors and regulators that obligations are being taken seriously.
ASIC’s 2025 review of responsible entities in managed investment schemes revealed just how critical these frameworks are. The findings pointed to weaknesses across the industry: unclear accountability, outdated structures, and plans that failed to reflect evolving obligations. While wholesale funds enjoy greater flexibility, the lessons apply directly. A plan that sits unchanged on paper quickly loses its value in practice.
Lessons From ASIC’s Findings
ASIC’s review highlighted three key pitfalls:
Templates aren’t enough — Off-the-shelf frameworks leave gaps as obligations change.
Every control needs an owner — Accountability is as important as process.
Static plans create risk — Compliance must adapt continuously, not once a year.
These are not issues confined to managed investment schemes. Wholesale operators face the same scrutiny when governance is weak or documentation falls behind.
Why Wholesale Funds Should Care
The regulatory environment for wholesale funds is shifting. Thresholds are under review, AML/CTF reforms are expanding, and ASIC has signalled closer attention to private markets. In this environment, a compliance plan that is generic or outdated is more than an administrative weakness — it is an operational risk.
Investors, too, now expect evidence of live compliance frameworks. They want to see monitoring, clear accountability, and governance that evolves with the landscape. A static plan may meet the minimum obligation, but it does not inspire confidence.
From Obligation to Oversight
At Wicklow, we help wholesale funds move compliance plans from obligation to oversight — ensuring they work in practice, not just on paper. That means:
Active monitoring that identifies gaps before they become failures.
Responsive frameworks that adapt to new obligations and market shifts.
Defined accountability so every control has an owner, and responsibility is clear.
This approach ensures compliance plans remain relevant, credible, and protective of both operators and investors.
Living Frameworks
Handled well, a compliance plan is not a static document. It is a living framework that evolves with a fund, protects against risk, and sustains credibility. For wholesale operators, the difference is clear: a plan that adapts builds confidence — a plan that doesn’t quickly becomes a liability.