Desk Fees Are Not the Enemy — GIM Trading Was the Exception, Not the Rule

In recent commentary, questions have been raised about the “desk fee” model used by many AFSL holders to cover their heavy compliance burdens. Some critics even call it “renting the licence,” which carries a negative connotation among people who don’t fully understand how compliance costs are structured.

At Bullseye Investigations, with professional grounding in financial services, we take a different view. Desk fees are simply one of several ways AFSL licensees recover the enormous costs imposed by ASIC compliance. The fee structure doesn’t drive misconduct — failures in supervision and verification do.

Understanding Desk Fees

A desk fee is a flat monthly payment made by an authorised representative to the licensee in exchange for operating under the AFSL. It’s no different to covering office rent or paying for a compliance officer’s time. It’s predictable, transparent, and gives the AFSL a steady cashflow to fund required oversight.

Other models exist — revenue sharing, transaction levies, or hybrid systems — but each comes with the same core obligation: the licensee must supervise, monitor, and enforce compliance. The Corporations Act doesn’t care how a licensee gets paid; it cares how they supervise.

Why GIM Trading Was an Anomaly

The case of GIM Trading shows how far professional fraudsters will go to create a veneer of legitimacy. The company was originally a legitimate business, later sold to operators linked to an overseas syndicate. They used:

• Virtual offices to appear credible in Collins Street, Melbourne

• Inflated claims of funds under management ($52 billion) and staff numbers (140 employees)

• Misrepresentation of AFSL status, long after they had lost the licence

• Multiple bank accounts to shuffle investor deposits out of reach

This was not a desk-fee problem. It was an impersonation and deception problem — a carefully staged scam that fooled even experienced investors. Desk fees did not enable the fraud.

What Really Matters: Verification

The key lesson from GIM is not “change the fee model.” It’s verification. Before investing, you should:

• Verify the AFSL number on ASIC’s Professional Registers

• Confirm the representative’s status with the licensee directly

• Check bank account details with the licensee before sending money

• Report suspicious behaviour to the licensee

Unfortunately, you must take these steps yourself, or engage a professional to conduct due diligence on your behalf.

Desk fees are a convenient target, but they are not the culprit. The real issue is bad actors exploiting gaps in investor verification. GIM Trading was a sophisticated anomaly, not evidence that the AFSL model is broken.

At Bullseye Investigations, we combine financial services knowledge with forensic investigation techniques to help victims of scams understand what went wrong — and, wherever possible, recover losses.

If you’ve been targeted by an investment scam, don’t just blame the model. Focus on the evidence, the money trail, and the recovery options.