Sam is a Senior Associate in the financial services regulation team. Sam’s work spans across all aspects of financial services regulation, including AML/CTF, payments laws, sanctions, financial services licensing, consumer credit, privacy, proceeds of crime legislation and money laundering offences.
He regularly advises global and domestic banks and financial institutions, payment service providers, remitters, government entities, digital platforms and marketplaces, industry associations, and gaming companies. Sam is at the forefront of regulatory developments, engaging consistently with regulators and presenting at industry events.
As a trusted advisor to many significant Australian and global businesses, Sam provides a wide range of legal support, including:
- advising on the regulatory treatment of businesses, products and services;
- preparing the architecture for compliance with applicable laws, including preparing customer and service agreements (in particular for compliance with the unfair terms regime), NCC-compliant lending documents, policies relating to sanctions, responsible lending and other compliance procedures;
- project-based advice, such as design and implementation of remediation plans, transformation projects to address legislative reforms, assessing findings of reviews and audits, and specialist advice in litigation and enforcement;
- transactional support, advising on the sale or purchase of regulated businesses, and drafting and negotiating white-label and other financial services partnership agreements.
His recent matter highlights include:
- Major Bank: Conducting a group-wide review to assess the treatment of all Australian and international products and services under the AML/CTF Act and advising on relevant regulatory obligations.
- Significant global payments provider: Providing ongoing comprehensive regulatory advice (including under payments laws, consumer credit, AML/CTF and other regimes) in relation to all products and services offered in Australia. This includes drafting disclosure documents, assisting with the launch of complex product offerings, and advising on the structure of, and drafting and negotiating contracts for, partnership arrangements relating to lending products.
- Mutual Bank and Credit Union: Leading the transactional and regulatory aspects of the transfer of a significant prepaid card portfolio, including drafting and negotiating agreements relating to disengagements with existing partners and the transfer, and engagement with relevant regulators.
- Major Bank: Advising on group-wide project to assess the impact of, and design and implement systems to address, reforms to the AML/CTF Act and the Scams Prevention Framework.
- Payment service provider: Advising on regulatory aspects (primarily AML/CTF and AFS licensing) relating to establishing payments acquiring business, including engagement with relevant regulators, obtaining a bespoke exemption, and drafting agreement suites.
- ASX100 Company: Advising on the structure, design and launch of white-labeled home loan product, including drafting and negotiating partnership agreements, advising on consumer credit laws and AFS licensing, preparing compliance documentation and providing training.
- Several banks, payment service providers, and gambling companies: Advising on enforcement investigations and actions brought by AUSTRAC and ASIC, including strategic advice on engagement, design and implementation of remediation programs, and compliance uplift relating to AML/CTF, AFS licensing and consumer credit.
