Leadership In Innovative Australian DEFI & Regulation at Hamilton Locke.
You have your finger on the pulse of the financial services industry.
What do you think are going to be the biggest industry trends for 2025?
The impact of the Australian and global economy on the financial services sector is always on our radar. Of course Donald Trump’s US Presidency is going to have a big impact on the financial services markets, and we’re already starting to see that reverberate through the stock market, and also digital assets/cryptocurrencies.
In 2025 we’re also going to see some major reforms around how Australia is going to regulate the digital assets sector, including cryptocurrency. We’re also going to see reforms on payments, because that has become an important and growing segment within the financial services industry in Australia.
We don’t use much cash in Australia anymore, and people are looking for alternative ways of paying. What we’re finding is there are lots of different payment solutions coming into the market – and that’s an area that’s ripe for reform and improved regulation, because the laws are very clunky in that space.
Anti-Money Laundering and Counter-Terrorism Financing are going to be an important area this year as an expanded range of people will need to comply within the laws.
We will see a continued focus on transparency about fees, charges and relationships between financial services companies. Even after the Royal Commission, there are still concerns about customers understanding the fees they pay for financial services and whether financial firms are managing conflicts of interest. Understanding whether a financial services provider has a bias towards giving advice on a particular product or provider is going to continue to be under the spotlight this year.
The impact of the Australian and global economy on the financial services sector is always on our radar. Of course Donald Trump’s US Presidency is going to have a big impact on the financial services markets, and we’re already starting to see that reverberate through the stock market, and also digital assets/cryptocurrencies.
In 2025 we’re also going to see some major reforms around how Australia is going to regulate the digital assets sector, including cryptocurrency. We’re also going to see reforms on payments, because that has become an important and growing segment within the financial services industry in Australia.
We don’t use much cash in Australia anymore, and people are looking for alternative ways of paying. What we’re finding is there are lots of different payment solutions coming into the market – and that’s an area that’s ripe for reform and improved regulation, because the laws are very clunky in that space.
Anti-Money Laundering and Counter-Terrorism Financing are going to be an important area this year as an expanded range of people will need to comply within the laws.
We will see a continued focus on transparency about fees, charges and relationships between financial services companies. Even after the Royal Commission, there are still concerns about customers understanding the fees they pay for financial services and whether financial firms are managing conflicts of interest. Understanding whether a financial services provider has a bias towards giving advice on a particular product or provider is going to continue to be under the spotlight this year.
We are going to see more regulator activity and legal actions brought by ASIC.
by Charmian Holmes
Partner, Head of Funds and Financial Services
Charmian is a highly regarded financial services regulation lawyer. She is known for her pragmatic and consensus based approach to legal and compliance issues. Whether she’s negotiating a sale, helping clients connect to do business or mentoring our up-and-coming lawyers, Charmian reads the room and puts people at ease with her down-to-earth nature.
Charmian provides legal and compliance advice to a broad range of financial services industry participants including insurance brokers, general insurers, underwriting agencies, fintechs and insurtechs. She is often engaged to provide legal sign off on product design and development and insurance distribution, including group purchasing arrangements. She is sought out for her niche expertise in innovative insurance solutions including parametric products, discretionary mutuals and aggregate deductible schemes.
Charmian advises on all aspects of financial services law, she loves nothing more than devising new risk products and solutions – like peer-to-peer models and other alternative risk vehicles. She also thrives on helping businesses grow and develop over time, from seed funding through to acquisition or IPO. Startups often seek her out when they need a sounding board to refine their ideas. She creatively finds new solutions that are within the boundaries of the law yet commercial in their execution.
Prior to joining Hamilton Locke, Charmian was a partner and co-founder of The Fold Legal, which merged with Hamilton Locke on 1 September 2022. Prior to that, she worked in the corporate and financial services team at Phillips Fox Lawyers (now DLA Piper).
AREAS OF EXPERTISE
Financial Services;
Partner, Head of Funds and Financial Services
Charmian is a highly regarded financial services regulation lawyer. She is known for her pragmatic and consensus based approach to legal and compliance issues. Whether she’s negotiating a sale, helping clients connect to do business or mentoring our up-and-coming lawyers, Charmian reads the room and puts people at ease with her down-to-earth nature.
Charmian provides legal and compliance advice to a broad range of financial services industry participants including insurance brokers, general insurers, underwriting agencies, fintechs and insurtechs. She is often engaged to provide legal sign off on product design and development and insurance distribution, including group purchasing arrangements. She is sought out for her niche expertise in innovative insurance solutions including parametric products, discretionary mutuals and aggregate deductible schemes.
Charmian advises on all aspects of financial services law, she loves nothing more than devising new risk products and solutions – like peer-to-peer models and other alternative risk vehicles. She also thrives on helping businesses grow and develop over time, from seed funding through to acquisition or IPO. Startups often seek her out when they need a sounding board to refine their ideas. She creatively finds new solutions that are within the boundaries of the law yet commercial in their execution.
Prior to joining Hamilton Locke, Charmian was a partner and co-founder of The Fold Legal, which merged with Hamilton Locke on 1 September 2022. Prior to that, she worked in the corporate and financial services team at Phillips Fox Lawyers (now DLA Piper).
AREAS OF EXPERTISE
Financial Services;
Insurance; Discretionary Mutuals; Insurtech; Fintech; Cryptocurrency; Regulatory; Corporate Advisory
AWARDS
AWARDS
Chambers and Partners, Fintech Legal Guide, Ranked Firm, Band 1, 2025
Chamber and Partners, Fintech Legal Guide, Ranked Lawyer, Band 3, 2025
Australasian Lawyer, Elite Women 2022
Chamber and Partners, Fintech Legal Guide, Ranked Lawyer, Band 2, 2019-2024
Lawyers Weekly, Partner of the Year Awards, Financial Services, Finalist 2022 and 2021
Fintech Business Awards, Fintech Thought Leader of the Year, 2019
Chambers and Partners, Fintech Legal Guide, Ranked Firm, Band 2, 2019 – 2022
Chambers and Partners, Asia-Pacific Guide, Financial Services Regulation, Ranked Firm, Band 4, 2020 – 2022
Client Choice Awards, Best Law & Related Services Specialist Firm (>$30m) – Banking & Finance, 2020, 2022
Client Choice Awards, Best Law & Related Services Specialist Firm (>$30m) – Insurance, 2021 – 2022
Fintech Australia, Finnies Award, ‘Excellence in Support Services’, Winner 2018, Finalist 2019 – 2022
QUALIFICATIONS
Chamber and Partners, Fintech Legal Guide, Ranked Lawyer, Band 3, 2025
Australasian Lawyer, Elite Women 2022
Chamber and Partners, Fintech Legal Guide, Ranked Lawyer, Band 2, 2019-2024
Lawyers Weekly, Partner of the Year Awards, Financial Services, Finalist 2022 and 2021
Fintech Business Awards, Fintech Thought Leader of the Year, 2019
Chambers and Partners, Fintech Legal Guide, Ranked Firm, Band 2, 2019 – 2022
Chambers and Partners, Asia-Pacific Guide, Financial Services Regulation, Ranked Firm, Band 4, 2020 – 2022
Client Choice Awards, Best Law & Related Services Specialist Firm (>$30m) – Banking & Finance, 2020, 2022
Client Choice Awards, Best Law & Related Services Specialist Firm (>$30m) – Insurance, 2021 – 2022
Fintech Australia, Finnies Award, ‘Excellence in Support Services’, Winner 2018, Finalist 2019 – 2022
QUALIFICATIONS
Bachelor of Arts, Bachelor of Laws – The University of Queensland
Admitted to practice in Queensland
SELECTED REPRESENTATIONS
Admitted to practice in Queensland
SELECTED REPRESENTATIONS
Appointed by Mitsui Sumitomo Insurance (Australian branch) (since 2020) to advise on financial services regulation and insurance product design and distribution and procurement and contracting arrangements, such as binder and master service agreements.
Advised Amtrust North America (since 2014) in relation to the accidental damage component of Microsoft Complete, an extended warranty and accidental damage product, offered to Australian customers to protect their Microsoft devices.
Appointed to the external legal panel for Arthur J. Gallagher & Co (Aus) Limited (since 2018) to advise on financial services regulation and licensing, insurance design and distribution, group purchasing body arrangements and commercial arrangements with insurers including agency, binder and SME insurance facilities.
Acted for Uber CarShare, Australia’s leading car-sharing platform owned by Uber, on the establishment of a discretionary mutual to protect exposures for borrowers and lenders to the car-sharing platform and advised on the impact of product design and distribution laws.
Acted for PICNIC Labs on their peer-to-peer insurtech model including Australian insurance regulation and the use of discretionary mutuals. We have acted for PICNIC on the launch of Our Ark Mutual – Australia’s first community based mutual supporting organisations in the religious, education, aged care and not-for-profit space to source risks.
Advised Zip Money on partnering with Cover Genius to offer product insurance for purchases made by customers using ZIP’s payment services including deferred sales model, hawking, design and distribution, financial services authorisations and privacy.
Advised KOBA Insurance, Australia’s first kilometre-based car insurance provider on their strategic alliance and authorised representative agreements, and all aspects of their go-to-market including website collateral, financial services guide and insurance documents, terms of business, privacy policy and terms of use.
Advised Open Insurance, an Australian and UK insurtech using APIs for the sale of the embedded insurance offers, on their partnering arrangements with Australian retailers including AHM and Telstra and financial services licensing and procurement arrangements.
Acts for CoinSpot, one of Australia’s largest cryptocurrency exchanges, since 2017 on a range of legal, corporate and regulatory matters.
Acted for Limepay in the establishment of a joint venture business with Domain Group and their pre-IPO convertible note issue.
Acted for BAC Insurance Brokers in a 50% sale of shares in the company to Steadfast Group Limited and separately for Westcourt General Insurance Brokers in the sale of their business to IAG Limited.

Brisbane
E:charmian.holmes@hamiltonlocke.com.au
T:+61 408 244 736
RELATED ARTICLES
Ctrl + Alt + Regulate – enhancing AI governance in Australia’s financial services sector
This is Us: Charmian Holmes
Legal 500 2025 Asia-Pacific guide ranks Hamilton Locke across multiple practice
Advised Amtrust North America (since 2014) in relation to the accidental damage component of Microsoft Complete, an extended warranty and accidental damage product, offered to Australian customers to protect their Microsoft devices.
Appointed to the external legal panel for Arthur J. Gallagher & Co (Aus) Limited (since 2018) to advise on financial services regulation and licensing, insurance design and distribution, group purchasing body arrangements and commercial arrangements with insurers including agency, binder and SME insurance facilities.
Acted for Uber CarShare, Australia’s leading car-sharing platform owned by Uber, on the establishment of a discretionary mutual to protect exposures for borrowers and lenders to the car-sharing platform and advised on the impact of product design and distribution laws.
Acted for PICNIC Labs on their peer-to-peer insurtech model including Australian insurance regulation and the use of discretionary mutuals. We have acted for PICNIC on the launch of Our Ark Mutual – Australia’s first community based mutual supporting organisations in the religious, education, aged care and not-for-profit space to source risks.
Advised Zip Money on partnering with Cover Genius to offer product insurance for purchases made by customers using ZIP’s payment services including deferred sales model, hawking, design and distribution, financial services authorisations and privacy.
Advised KOBA Insurance, Australia’s first kilometre-based car insurance provider on their strategic alliance and authorised representative agreements, and all aspects of their go-to-market including website collateral, financial services guide and insurance documents, terms of business, privacy policy and terms of use.
Advised Open Insurance, an Australian and UK insurtech using APIs for the sale of the embedded insurance offers, on their partnering arrangements with Australian retailers including AHM and Telstra and financial services licensing and procurement arrangements.
Acts for CoinSpot, one of Australia’s largest cryptocurrency exchanges, since 2017 on a range of legal, corporate and regulatory matters.
Acted for Limepay in the establishment of a joint venture business with Domain Group and their pre-IPO convertible note issue.
Acted for BAC Insurance Brokers in a 50% sale of shares in the company to Steadfast Group Limited and separately for Westcourt General Insurance Brokers in the sale of their business to IAG Limited.

Brisbane
E:charmian.holmes@hamiltonlocke.com.au
T:+61 408 244 736
RELATED ARTICLES
Ctrl + Alt + Regulate – enhancing AI governance in Australia’s financial services sector
This is Us: Charmian Holmes
Legal 500 2025 Asia-Pacific guide ranks Hamilton Locke across multiple practice