Naomi Fink

LinkedinSpecial Counsel

Naomi has worked with Holley Nethercote Lawyers since 2002, and has expertise in financial crime and commercial law.  She provides AML/CTF advice, independent reviews or drafts tailored AML/CTF Programs, and delivers AML/CTF training via Holley Nethercote Lawyers’ training arm, Holley Nethercote Compliance.  Naomi also provides commercial advice in the areas of employment, occupational health and safety, leasing, franchising, financial services, privacy, and works in the trade practices and intellectual property areas.

Admitted to Practice


Key Areas of Expertise

  • Anti-money laundering – preparing AML programs, helping clients deal with AUSTRAC
  • Franchising – (acting for franchisors)
  • Employment agreements, including advising on restraints of trade, award obligations
  • Commercial agreements – licensing, services, supply, shareholder
  • Intellectual property – trade marks and copyright
  • Leases
  • Sale of business agreements
  • Authorised representative agreements

Career Achievements

  • Helping clients avoid further regulatory action by assisting putting in place trade practices compliance framework.


  • Bachelor of Law/Arts - Monash University

Favourite Quote

“Sometimes the questions are complicated and the answers are simple.” — Dr. Seuss

My Thoughts

Why your AML/CTF Program needs to be independently reviewed regularly

25 Sep 2023

We have conducted lots of independent reviews.  In this article we explain who the review obligations apply to, who can undertake them, where they come from, and what to expect. If you provide financial, lending,…

What’s the difference between a standard AML program and one that a financial adviser needs (also called a “special program”)?

16 Feb 2022

If a business or entity provides one or more designated services (listed in section 6 of the AML/CTF Act) and is geographically linked to Australia, it will be required to comply with the obligations set…

Keeping your AML/CTF Program up-to-date

01 Apr 2021

Outsourcing KYC obligations If you are bound by the Australian Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) legislation[1], (that is, you are a “reporting entity”), you must have in place policies and procedures which manage the…

What is an AML/CTF Program and do I need a Risk Assessment?

08 Sep 2020

Do I need an AML/CTF Program? Yes - if you are a “reporting entity” and you provide a “designated service” in connection with Australia that meets the “geographical link” test and if no exceptions apply. …

FACT SHEET: How to set up a Money Remitter (also known as a Money Transfer Operator or Payment Services Provider) Checklist

19 Jun 2020

☐ Determine the characteristics of your remittance business Payment corridors and any other jurisdictions you will deal with Currencies you will exchange Customer types Whether your business offers only spot FX or also forward or option…

How will my commercial contract be affected by COVID-19?

31 Mar 2020

We are all aware of the impact of COVID-19 on our health system and social interactions, however it is also important to consider the effect of the pandemic on business. Quarantine measures and shutdown directions…

Changes to annualised salary arrangements: from 1 March 2020

13 Feb 2020

Is your industry subject to a Modern Award?  If yes, does the Award include an “annualised salary” provision?  If yes, then from 1 March 2020, you must comply with new notification and record-keeping requirements. What…

Complying with your AML/CTF obligations

12 Feb 2020

AUSTRAC Action: The Westpac Case AML/CTF obligations - A case study: Australian Transaction Reports and Analysis Centre (AUSTRAC) made national and international headlines on 20 November 2019, when it applied to the Federal Court for…

Enhanced Whistleblower Protections: What does it mean for your Company?

27 Jun 2019

As of 1 July 2019, potential whistleblowers across Australia will enjoy an added layer of statutory protections.  The Treasury Laws Amendment (Enhancing Whistleblower Protections) Act 2019 (Cth) (‘the Amendment’) has expanded the whistleblower protections previously contained in…

Cryptocurrency Exchanges must now fully comply with the Anti-Money Laundering and Counter-Terrorism Laws in Australia

04 Oct 2018

  If you are operating a cryptocurrency/digital currency exchange (DCE) which exchanges fiat (Australian or foreign currency) for digital currency and/or vice versa, you would be aware that from 3 April 2018, you have had…

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