Produced By: Ensombl
Compliance in financial services has never been more vital—or more complex. Changing regulations, administrative burdens, and heightened client expectations have reshaped the way Australian Financial Services Licensees (AFSLs) must operate. Amid all this, businesses continue to seek ways to uphold ethical standards and professional conduct while also managing commercial needs.
In a recent conversation, Patrick Gardner, host of a podcast dedicated to the world of AdviceTech and compliance, sat down with two experts at the forefront of RegTech innovation. Eloise Somerford and Julia Vojkovic, co-founders of the company behind the “Three Lines” platform, shared their insights on building a culture of compliance within AFSLs. Their company has embarked on a mission to streamline all aspects of compliance—ranging from complaint handling to advisor reviews—while fostering a deep commitment to ethics and professionalism.
Below is an in-depth look at how their journey began, the way technology has evolved to meet AFSL obligations, and how artificial intelligence (AI) will shape the future of compliance management.
One of the more lighthearted parts of the conversation revolved around each guest’s “oldest piece of technology.” Eloise spoke fondly of her “purple Lumix,” an early-2000s digital camera that conjured memories of uploading hundreds of photos to MySpace. Meanwhile, Julia still relies on her 2003 model GHD hair straightener, using it every day and marveling that it has outlasted multiple new tech gadgets.
What began as a playful discussion about nostalgic devices soon pivoted into a larger reflection on how much technology has progressed in just two decades. Nearly every aspect of modern life—both personal and professional—relies on software, connectivity, and, increasingly, artificial intelligence. Where a digital camera was once an exciting innovation for capturing memories, advanced AI platforms are now revolutionizing how businesses maintain ethical and professional standards, such as meeting compliance obligations and providing better client experiences.
In exploring the personal applications of AI, Julia confessed that she uses it to help draft letters, emails, and even cover letters for job applications. Whether it’s easing writer’s block or generating fresh ideas, AI tools have become a go-to assistant for everyday communication.
Eloise took it a step further, noting how she once challenged herself to use AI for every daily task over a seven-day period. From meal planning to emails, AI offered structured support and simplified tasks. However, she also discovered clear limitations and the necessity of human oversight. Humorously, Eloise’s children attempted to create AI-generated images of “Trump wearing a tutu, jumping on a trampoline,” only to find that the model drew certain ethical and content-related lines.
These anecdotes highlight the dual nature of AI: immensely helpful but also bound by constraints—some practical, some ethical. For financial services professionals and AFSL holders, this cautionary tale underscores the importance of viewing AI as a powerful tool to be integrated responsibly, especially where professional judgment and regulatory standards come into play.
Long before they were RegTech pioneers, Eloise and Julia started out in roles that gave them unique vantage points on the Australian financial regulatory landscape. Julia launched her career through ASIC’s graduate program, where she investigated high-profile cases. Eloise, meanwhile, worked in the Big Four consulting world—PwC, EY, and Deloitte—before eventually joining ASIC.
Their paths converged at Macquarie Private Wealth, which was undergoing an enforceable undertaking at the time. Both women were shortlisted for the same compliance manager role in Perth. When the hiring manager, Tony, found himself unable to choose between the two equally qualified candidates, he simply hired both. This serendipitous decision brought Eloise and Julia together, forming a partnership that would shape the future of compliance technology.
Experiencing firsthand how even a large AFSL could struggle to keep compliance both efficient and commercial, they left Macquarie to found Compliance Code, a consulting firm designed to guide small to medium licensees through the labyrinth of ASIC regulations. As their client base grew, so did their administrative workload. Battling unwieldy spreadsheets and repetitive manual tasks, they sought an “off-the-shelf” compliance solution—and came up empty-handed. Everything was either too expensive, too complicated, or solved only part of the problem.
Thus began their journey toward building their own compliance platform: Three Lines. It started simply as an internal tool to keep track of tasks, registers, and reviews across multiple clients. But when the firm’s clients began asking how they managed so much complexity so smoothly, Eloise and Julia realized they had inadvertently built something valuable to the entire industry.
Since its modest beginnings, Three Lines has evolved into a SaaS (Software as a Service) platform that covers the core needs of any AFSL. It consolidates registers, file reviews, complaint management, compliance committee meetings, and even professional year (PY) management into one central location. The ethos behind the platform is both straightforward and sweeping: reduce manual duplication and confusion, while instilling best practices in ethics and professionalism.
Despite its origins in managing smaller licenses, Three Lines has proven scalable. FINDEX, one of Australia’s larger professional services and financial advice networks, adopted Three Lines to manage hundreds of advisors across accounting, tax, and investment platforms. Their successful onboarding demonstrated that general obligations under an AFSL remain consistent regardless of firm size; the difference lies in the number of users, the volume of data, and complexity.
Following user feedback, Eloise and Julia introduced Three Lines 2.0 in 2023, a rebuild that modernized the backend code while introducing new features. They also launched a “light version”—free to use with no contract or hidden fees—so smaller or newly established licensees can start managing their compliance requirements (like IDR registers and policy hosting) immediately. Firms can upgrade to premium or enterprise tiers seamlessly once they need a more holistic toolkit.
Beyond the technical specifications and user-friendly design, the Three Lines founders consistently emphasize the importance of professionalism and ethics. Compliance isn’t merely a box-ticking exercise; it is central to the trust between a financial advisor and their client. In an industry where reputations can be made or broken based on regulatory penalties or breaches, systems like Three Lines serve as both a protective mechanism and a means to elevate the standard of care.
Financial advisors in Australia operate under a range of regulatory obligations. From RG 146 requirements for competency, to RG 271 on internal dispute resolution, they must not only demonstrate technical competence but also uphold higher-order ethical principles like honesty, integrity, transparency, and a client-first mindset.
In practice, that means having consistent and repeatable processes for tasks like file reviews, complaint handling, and ongoing monitoring. A robust platform ensures that no issue or oversight falls through the cracks, which is essential for maintaining professional credibility.
Ethics in financial services often intersects with practical challenges. For instance, when a complaint arises, do advisors diligently report it, or are they inclined to downplay it? With an IDR tool automatically evaluating the language or sentiment of client interactions, Three Lines counters any temptation to “hide” a complaint. The system ensures that every expression of dissatisfaction—whether explicit or implicit—is handled with diligence.
Another ethical dimension emerges with the use of artificial intelligence. AI can supercharge compliance oversight, but also introduces privacy, confidentiality, and data-use considerations. Firms must be able to trust that any data fed into AI tools will not be shared or employed to train external models without explicit, informed consent. This is non-negotiable in an industry where client confidentiality is paramount.
Both Eloise and Julia are vocal proponents of using AI responsibly. They envision a future where machine learning algorithms rapidly flag potential red flags across thousands of data points, pre-screen advice documents, and interpret regulatory changes at scale. Yet, they caution against seeing AI as a “magic bullet.” Instead, they suggest AI be integrated in ways that enhance, rather than replace, human professional judgment.
The conversation revealed a sneak peek at “QuickVet,” a new feature they plan to roll out in late 2023. QuickVet will facilitate pre-vet checks of advice documents—offering a swift, AI-powered review that highlights possible compliance missteps before advice ever reaches the client. This proactive approach stands to reduce the likelihood of post-advice remediation and fosters a “get-it-right-the-first-time” culture.
When adopting AI in compliance, licensees must:
In an industry as regulated as financial services, professionalism and ethics are not tangential: they are the foundation of every business interaction. Adopting RegTech solutions that systematically guide and enforce these standards can be a game changer.
Professionalism is reflected in timeliness, consistency, and the courage to own up to mistakes. For example, meeting minutes are no longer an afterthought or a scribbled note in a spiral notebook; they become automated records with designated action items, timelines, and accountability. That level of structure ensures each participant in a compliance committee meeting understands their responsibilities, fulfilling them in a traceable, verifiable manner.
Ethics come into play when technology reduces the gray areas that can lead to misconduct or oversights. When an AFSL or advisor is fully informed—thanks to real-time or near-real-time regulatory updates—they are less likely to commit inadvertent infractions. Transparency around tasks and potential breaches further deters unethical behavior. After all, if every action is logged in a central system and automatically assigned to an individual, there is a smaller window for ignoring compliance duties or shifting blame.
The path to creating Three Lines wasn’t a straight one. Eloise and Julia liken the platform rebuilds to a home renovation—disruptive at times, but essential for long-term growth and improvement. In doing so, they learned several lessons:
One of the biggest hurdles for AFSLs is fragmentation. Multiple systems for compliance activities—spreadsheets for registers, disparate apps for file reviews, scattered documentation—leads to confusion and potential mistakes. A single misstep in data entry could cascade into a breach.
This fragmentation also affects firm culture. A robust compliance culture demands clarity: each person knows their role, and leadership knows how to track tasks without micromanaging. By consolidating these functionalities—complaints, advisor reviews, meeting records—into one system, Three Lines helps licensees access a “single source of truth.”
This integrated approach frees business owners and directors to focus on delivering quality client outcomes rather than chasing stale spreadsheets. For newly minted licensees, starting with a well-structured system avoids the headache of retroactive fixes later. For established enterprises, the transition can unify previously disconnected data, creating a more cohesive compliance environment.
An unspoken theme in the conversation with Eloise and Julia is adaptability. The financial services industry, particularly in Australia, is in a perpetual state of transformation—whether through legislative change, technological leaps, or shifting consumer expectations. Firms that cling to manual systems or half-baked “quick fixes” run the risk of non-compliance, reputational harm, and missed opportunities to genuinely serve clients better.
Professionalism and ethics are not “nice to have.” They underpin the viability of a financial services business. Clients are more informed than ever, and trust is a delicate currency. One well-publicized breach can corrode a firm’s credibility. Conversely, a proven track record of ethical conduct and robust processes can set a firm apart, contributing to client loyalty and business sustainability.
Adopting RegTech platforms that incorporate AI, integrated compliance processes, and real-time monitoring is quickly becoming an industry standard rather than a niche innovation. The difference going forward will be how effectively such platforms can respect and reinforce the duty of care required in finance. The best solutions will combine the efficiency of AI with the irreplaceable insight of human professionals committed to doing the right thing.
In concluding their conversation, Patrick Gardner thanked Eloise and Julia for their dedication to “making compliance great again.” The phrase, humorous yet apt, underscores a broader movement: compliance need not be burdensome when approached with the right mindset and the right technology. By weaving professional conduct and ethical duties into every interaction—internally with staff and externally with clients—firms not only protect themselves against regulatory risk but also build a positive reputation and a lasting legacy.
For those curious to see how Three Lines can simplify AFSL compliance, Julia and Eloise recommend starting with the free Three Lines “light” account. This immediate, no-cost entry point allows new licensees or curious onlookers to explore the platform’s registers, IDR functions, and policy-hosting features. If the need for more advanced functionalities arises—like comprehensive advisor reviews, complex group structures, or the forthcoming QuickVet AI—the platform’s premium and enterprise tiers can scale accordingly.
Ultimately, true professionalism and ethics in financial services are sustained by continual learning, adaptation, and the thoughtful integration of technology. Platforms like Three Lines signal a future where compliance is not a frantic afterthought but a proactive, core business function. With regulatory pressures unlikely to ease anytime soon, the industry’s mission is clear: blend innovation and integrity so that both clients and professionals can thrive in a rapidly evolving landscape.
Accreditation Points Allocation:
0.10 Technical Competence
0.10 Client Care and Practice
0.10 Regulatory Compliance and Consumer Protection
0.10 Professionalism and Ethics
0.40 Total CPD Points