ASIC Bans Former Sequoia and Interprac Director Garry Crole for 10 Years

Key Takeaways

• ASIC has banned Garry Crole, former director and responsible manager of Interprac Financial Planning and former Sequoia Financial Group CEO, from financial services director and responsible manager roles for 10 years.
• The ban stems from his failure to respond to known concerns about authorized representatives' advice models and inadequate oversight of the approved product list, which included the now-collapsed First Guardian and Shield Master Funds.
• This action underscores ASIC's continued focus on individual accountability for licensee oversight failures connected to superannuation advice misconduct.

Deep Dive

This action is part of a broader ASIC enforcement campaign targeting individuals and entities connected to the collapse of the First Guardian Master Fund and Shield Master Fund, which has resulted in significant superannuation losses for retail clients. Mr. Crole's ban follows related actions against Rhys Reilly, Ferras Merhi, and ongoing proceedings against Interprac itself, indicating a coordinated regulatory response addressing systemic failures in advice oversight, product approval governance, and licensee responsible manager duties.

For compliance teams, this case highlights the critical importance of robust approved product list (APL) governance and active monitoring of authorized representatives, particularly where lead generation models or high-volume superannuation rollover advice is involved. ASIC's findings that Mr. Crole was aware of concerns regarding the advice model but failed to act demonstrate that passive awareness without remedial action will not satisfy fit and proper person standards. Directors and responsible managers must be able to evidence proactive escalation, investigation, and decisive action when red flags arise regarding representative conduct or product suitability.

Key timeline considerations include the retrospective nature of the findings, covering conduct from 2004 through 2026, demonstrating ASIC's willingness to examine historical oversight failures spanning extended periods. The banning order took effect September 4, 2026, with Mr. Crole retaining appeal rights to the Administrative Review Tribunal, meaning this matter may see further developments.

Recommended actions for compliance professionals include conducting immediate reviews of APL governance frameworks, particularly for high-risk products or those sourced through third-party introducers; strengthening escalation protocols for concerns about authorized representative conduct; and ensuring responsible managers can demonstrate active, documented oversight rather than passive licensing arrangements. Firms with authorized representative networks, especially those using lead generation or high-volume superannuation advice models, should conduct risk assessments against the practices identified in this and related ASIC actions (25-274MR, 25-184MR, 25-249MR, 26-073MR) to identify and remediate similar vulnerabilities before they attract regulatory scrutiny.

Source: Australian Securities and Investments Commission