About the role

FivePearls Funds Management is an early-stage fund manager running wholesale funds, including a cash fund trust with pooled investor sub-funds and a first mortgage fund. The trustee and investment manager sit in the same group, and fund administration (accounting, unit pricing and registry) is run in-house.

This is a build role. You will own compliance at FivePearls: design the framework, processes and systems from the ground up, then run them. You will give the Responsible Managers assurance over the trustee's duties and the AFSL obligations, and shape how compliance scales as the funds grow.

Key responsibilities

Build the compliance function

- Design and implement the compliance framework, policies and compliance calendar, sized for an emerging manager and built to scale.
- Map the trustee and AFSL obligations across both funds into one obligations register, with an owner and a control for each.
- Design the controls that separate the trustee and manager functions within the group, including sign-off authorities, conflicts approvals and separate minutes.
- Build maker-checker and review processes around in-house unit pricing, fund accounting, registry and AML/KYC.
- Select and implement compliance tooling for registers, workflow, monitoring and attestations, automating manual checks where it makes sense.
- Write the procedures and templates staff use day to day, and train them on them.
- Make FivePearls due-diligence ready, with the policies, evidence and reporting that investors, platforms and research houses ask for.

Trustee oversight and monitoring
- Monitor that the investment manager lends within each fund's mandate, trust deed and concentration limits, and escalate exceptions.
- Review portfolio, arrears and breach reporting from the investment manager to the trustee.
- Check that execution of mortgages,



discharges and variations follows trustee sign-off authorities.
- Monitor that enforcement and workout actions are properly authorised by the trustee.
- Check fees charged to the funds against the trust deeds and information memoranda.
- Maintain oversight of conflicts and related-party dealings, and that approvals follow the documented path.
- Review controls over in-house unit pricing, fund accounting and distributions, including maker-checker processes.
- Oversee investor onboarding, AML/CTF and KYC processes, and registry accuracy.
- Monitor service providers (auditor, valuers, loan servicer) against their agreements.
- Monitor the investment manager's performance under the management agreement.

AFSL compliance (investment manager)
- Keep the AFSL compliance framework, policies and calendar current as the business grows.
- Assess incidents for breach reportability and prepare reports to ASIC within required timeframes.
- Support the Responsible Managers in meeting licence conditions, and in keeping RM and staff competency and training records current.
- Oversee internal dispute resolution and AFCA membership requirements.
- Review marketing materials and information memoranda for compliance before release.
- Track regulatory change and advise on its impact on both funds.

Run it day to day
- Maintain the breach, incident and complaints registers end to end.




- Prepare monthly compliance reports to the Responsible Managers and quarterly reports to the trustee and manager boards.
- Attend board and committee meetings as required, and keep trustee and manager compliance minutes separate.
- Coordinate external compliance reviews and audits.

About you

Essential
- 5–8 years in compliance, risk or governance within Australian funds management or financial services.
- A track record of building or substantially rebuilding a compliance framework, process or system, not only operating one.
- Working knowledge of the Corporations Act, AFSL obligations, ASIC breach reporting and AML/CTF requirements.
- Experience with trust structures and the trustee–manager relationship.
- Comfort working without a playbook: you set the structure rather than wait for it.
- A practical, proportionate approach, designing controls that fit an emerging manager and still stand up to investor due diligence.
- The confidence to raise issues with senior management, with clear writing and close attention to detail.

Preferred
- Experience in private credit, mortgage lending or a mortgage fund.
- A tertiary or qualified qualification in law, compliance or governance, risk and compliance (GRC).
- Experience setting up compliance at a start-up or emerging manager.
- Hands-on experience implementing GRC software or automating compliance workflows.
- Exposure to wholesale unregistered managed investment schemes, and to businesses that run fund administration in-house.

What we offer
- A competitive remuneration package.
- Ownership of the compliance function from day one, with a blank page to design it well.
- Direct access to the Responsible Managers and a real say in how the business is built.
- The chance to grow the function, and your role, as FivePearls grows.

📌 Compliance Manager (Sydney)
🏢 FivePearls Property Funds
📍 Sydney