ASIC is investigating the management and operation of the Shield Master Fund (Shield), a managed investment scheme. Keystone Asset Management Ltd (KAM) is the responsible entity of the scheme and is now in liquidation.
ASIC understands that investments were made into Shield by around 5,800 investors, who accessed Shield primarily through superannuation platforms, the trustees for which were Macquarie Investment Management Limited (Macquarie) and Equity Trustees Superannuation Limited (Equity Trustees).
ASIC’s investigation to date suggests that many of those investors were called by lead generators and referred to personal financial advice providers who advised them to roll their superannuation assets into a retail superannuation fund available on a choice platform, and then invest into Shield. Some investors received advice to set up self-managed superannuation funds (SMSFs) to facilitate investments into Shield.
ASIC’s investigation into Shield and its officers and related entities, is part of ASIC’s broader consideration of matters concerning Shield and is ongoing.
ASIC will update this webpage when important steps take place in relation to this matter. We suggest you visit this page regularly for updates. The liquidators also have a webpage about the status of the liquidation at A&M’s website.
Important information for investors
If you have concerns about the financial advice you received or about your superannuation trustee, you may wish to consider lodging a complaint with the Australian Financial Complaints Authority (AFCA). AFCA is the external dispute resolution scheme for financial complaints in Australia and must deal with complaints independently and fairly. AFCA’s service is free for consumers.
AFCA can be contacted by:
calling 1800 931 678 for free (9am – 5pm Melbourne time), or
AFCA can only deal with complaints where the financial firm is a member of AFCA. Many Australian financial services (AFS) licensees are required to be members of AFCA. You can search for members of AFCA on their website: Financial Firm Search - Customer Self-Service. AFCA has a dedicated website in respect of Shield on its Current Matters webpage. We have listed the main AFS licensees below with their associated AFCA Member Number:
ASIC cancelled MWL’s Australian financial services licence on 25 August 2025.
In cancelling MWL’s licence, ASIC required MWL to remain a member of AFCA until 25 August 2026.If you intend to lodge a complaint with AFCA in relation to advice received from MWL you should do so by 25 August 2026.
5 Point Australia Pty Ltd (ACN 661 120 583) (in liquidation)
AS Financial Planning Pty Ltd (ACN 666 648 942) (in liquidation)
STC Financial Pty Ltd (ACN 669 888 984) (in liquidation)
Contact details:
admin@fsga.com.au
(03) 9961 0524
ASIC cancelled FSGA’s Australian financial services licence on 7 June 2025.
In cancelling FSGA’s licence, ASIC required FSGA to remain a member of AFCA until 4 June 2026. If you intend to lodge a complaint with AFCA in relation to advice received from FSGA you should do so by 4 June 2026.
On 18 October 2024, ASIC cancelled the Australian financial services (AFS) licence of Next Generation Advice Pty Ltd (in Liquidation).
ASIC has specified that Next Gen must continue its membership of AFCA until 17 October 2025. If you intend to lodge a complaint with AFCA in relation to advice received from Next Gen, you should do so by 17 October 2025.
AFCA also has important information for self-managed superannuation fund (SMSF) trustees on their website: Factsheet – SMSF complaints.
If you have concerns about your superannuation trustee, please find details of the relevant AFCA Member below:
KAM suspended redemptions in February 2024. You cannot transfer or withdraw your investment as all redemptions are frozen due to the liquidation so that the overall financial position of the fund and recoverability of the fund’s investments can be assessed by the liquidators.
Following concerns raised by ASIC, the Federal Court appointed receivers to KAM. ASIC sought orders to preserve the assets of the scheme so that they may be recovered, to the extent available, for the benefit of investors while the investigation is continuing. The appointed liquidators and receivers are investigating the financial position of Shield and KAM and have commenced legal proceedings to recover investor funds: see Significant Event Notice dated 13 December 2024. The liquidators will keep unitholders informed and will provide updates on their website with respect to any material developments: A&M website.
On 22 November 2024, the receivers published a Significant Event Notice which provided a preliminary estimate of returns for unitholders and contains detailed information of the sources and uses of investor funds.
On 22 November 2024, the liquidators published a Significant Event Notice which provided a preliminary estimate of returns for investors.
Whether any money is returned depends on available assets, court outcomes and the results of liquidation and recovery proceedings.
On 15 August 2025, the Receivers issued a Notice Calling for Proofs of Debt to Creditors advising that they have identified assets which may be distributed to qualifying unit holders of Shield, from property held by KAM in its capacity as responsible entity of Shield. In the Notice, the Receivers confirmed that they intend to apply to the Court for authorisation to proceed with an interim distribution to qualifying unit holders.
The liquidators have published a webpage where they are providing updates in respect of KAM and the Shield Master Fund, which is available here: A&M website.
Unfortunately, ASIC is not able to provide any information, documents or advice specific to your investment.
If your investment was facilitated through a superannuation platform, you may wish to contact your superannuation trustee for further information about your investment. If you have concerns about your superannuation or investment platform provider, you may wish to consider lodging a complaint with AFCA.
Be alert—we are aware of emails impersonating professional firms that claim to be able to recover lost funds or provide compensation. These may include links to websites requesting login details and other personal or financial information.
ASIC strongly recommends you not to click on any links or respond to these messages or emails.
ASIC’s Moneysmart website includes guidance that unexpected contact, constant contact and pressure to take action or make a quick decision are warning signs of scams: Protect yourself from scams.
Moneysmart also provides guidance to hang up the call, or block emails or text messages, if someone offers from a third-party organisation to recover lost funds, or claims they can recover your losses for a percentage of the recovered losses or for a fee they say is a ‘tax’, ‘deposit’, ‘retainer’ or ‘refundable insurance bond’: What to do if you've been scammed.
Former clients still have the right to lodge a complaint with AFCA for up to one year from the date of licence cancellation, provided the conduct occurred while the firm was licenced.
If you intend to lodge a complaint with AFCA in relation to advice received from FSGA or its authorised representatives you should do so by4 June 2026.
If you intend to lodge a complaint with AFCA in relation to advice received from Next Gen, you should do so by 17 October 2025. Further information in relation to Next Gen’s licence cancellation can be found on ASIC’s website: 24-235MR ASIC cancels AFS licence of Next Generation Advice.
If you intend to lodge a complaint with AFCA in relation to advice received from MWL Financial Services Pty Ltd (MWL), you should do so by 25 August 2026. Further information in relation to MWL’s licence cancellation can be found on ASIC’s website: 25-181MR ASIC cancels AFS licence of MWL Financial Services and bans MWL’s director.
If your investment in Shield was made through a SMSF you may wish to consider contacting your accountant or seek independent financial advice. ASIC’s Moneysmart website has information on how to choose a financial adviser.
AFCA also has important information on its website which outlines who can bring a complaint to AFCA about advice or services provided to a SMSF: Factsheet – SMSF complaints.
The liquidators have published a webpage where they are providing updates in respect of KAM and the Shield Master Fund, which is available here: A&M website.
For further detail as to why ASIC took this action, see the Updates section above. ASIC cannot comment on its open investigation further than what is available through its court actions.
ASIC has set out its approach to enforcement in Information Sheet 151ASIC’s approach to enforcement. ASIC considers a number of factors when deciding if enforcement action is appropriate to address particular misconduct, such as the seriousness of the alleged misconduct, its impact on the confidence of investors and financial consumers, and the consequences of the misconduct for investors and others.
Due to the scale and complexity of the investigation, we cannot estimate how long it will take.
We understand this may be a difficult time for you. Further support is available if you need it.
If you are experiencing financial difficulty, you can speak to an independent financial counsellor for free by contacting the National Debt Helpline (NDH) on 1800 007 007 (9:30am to 4.30pm in your local Australian time zone, Monday to Friday). The NDH may not be able to assist with your specific investment.
You can also find a financial counselling agency using the map on ASIC’s Moneysmart website.
You may be able to obtain free independent legal advice from a community legal centre – You can search for your local community legal centre here: Legal Help – CLCs Australia.
Justice Connect may be able to link eligible individuals with firms and barristers that may be able to provide pro bono legal advice. You can visit the Justice Connect webpage here: Home – Justice Connect for more information.
If you are experiencing a mental health crisis and want to talk to someone straight away the following services operate 24/7:
Lifeline
Lifeline Crisis Support – 13 11 14
They also offer online chat and text crisis services.
The Beyond Blue Support Service is available 24/7 for brief counselling. You can call them on 1300 22 4636 or chat to them online. They also have a variety of other mental health supports you can access.
This website provides a listing of Registered Psychologists, including areas of specialty and location: Find a Psychologist | APS
Psychologists set their own fees so there may also be a gap between what Medicare will pay and what is charged. Some psychologists do not provide a Medicare rebate so it is best to ask about fees prior to your session
If you are experiencing family violence including economic abuse you can contact the National domestic violence service – 1800Respect on 1800 737 732: Home | 1800RESPECT
Updates
On 7 February 2024, ASIC issued interim stop orders to prevent new investment in the Shield Master Fund due to concerns about four product disclosure statements (PDSs) for Shield. The interim orders stopped KAM from offering, issuing, selling or transferring interests in the Balanced class, Growth class, High Growth class and Conservative class units of Shield. ASIC made the interim orders to protect retail investors from acquiring products under PDSs that may be defective (24-018MR).
On 18 June 2024, the Federal Court made interim orders preserving the assets of KAM to help protect investor funds while an investigation is continuing (24-129MR). ASIC has taken a range of Court actions in respect of KAM and in seeking orders from the Court, ASIC alleged that:
KAM is the trustee of the Advantage Diversified Property Fund (ADPF), a wholesale property fund into which a large proportion of Shield’s funds have been invested
the ADPF has made loans to various companies associated with Paul Chiodo (former director of KAM) to fund property development projects in Fiji, Italy, Port Douglas, and Melbourne
substantial sums appear to have been spent on property developments without written contracts and in the case of the Port Douglas development, without the requisite development approvals to proceed
there is a substantial shortfall when comparing the monies invested in the ADPF against the value of the assets of the ADPF, and
investor funds may have been misapplied.
On 26 June 2024, Mr Tracy and Ms Palaghia of Deloitte were appointed by the Federal Court to take control of Shield’s bank accounts and provide a report on its financial position (24-137MR).
On 27 August 2024, the Federal Court made orders appointing Mr Tracy and Ms Palaghia of Deloitte as receivers and managers of the property of KAM. The receivers are required to:
secure property held by KAM in its capacity as responsible entity of Shield and trustee of certain other funds
investigate how Shield investor money was used by KAM, and
“The extent of Keystone’s mismanagement confirms that there is a need to protect the interests of investors from what appear to be conflicts of interest and breaches of trusts…On the basis of the material before the Court, I do not have confidence that the SMF [Shield Master Fund] and ADPF [Advantage Diversified Property Fund] are being managed in the best interests of investors, or that Keystone is capable of providing such management…there are real doubts about the status and value of investments in the SMF and ADPF.”
On 28 August 2024, KAM’s directors appointed Scott Langdon, John Mouawad and Michael Korda of KordaMentha as voluntary administrators of KAM.
On 5 September 2024, the Federal Court made orders removing Scott Langdon, Michael Korda and John Mouawad of KordaMentha as voluntary administrators and appointed Mr Tracy and Ms Palaghia of Deloitte as voluntary administrators in addition to their role as receivers (24-197MR).
On 18 October 2024, ASIC cancelled the Australian financial services (AFS) licence of Next Generation Advice Pty Ltd (in Liquidation) (Next Gen). If you intend to lodge a complaint with AFCA in relation to advice received from Next Gen, you should do so by 17 October 2025.
On 22 November 2024, the liquidators published a Significant Event Notice which provided a preliminary estimate of returns for unitholders. The receivers have commenced legal proceedings on behalf of KAM and have frozen further monies: for further detail see Significant Event Notice dated 13 December 2024.
On 2 December 2024, creditors voted to wind up KAM. Jason Tracy and Glen Kanevsky of Deloitte were appointed joint and several liquidators (24-265MR).
In February 2025 and March 2025, the Federal Court made interim orders freezing assets of persons connected to the Shield investigation including:
Osama Saad, former director of Aus Super Compare Pty Ltd (in liquidation) and Atlas Marketing Pty Ltd (in liquidation) (25-023MR)
Ferras Merhi of Venture Egg Financial Services Pty Ltd & United Financial Advice Pty Ltd t/as Venture Egg (Venture Egg) and Financial Services Group Australia Pty Ltd (FSGA) (25-024MR), and
Rashid Alshakshir, director of Lion & Horn Pty Ltd (in liquidation), Nohap Pty Ltd (in liquidation) and Indigo Group Pty Ltd (in liquidation) (25-043MR).
On 10 April 2025, the liquidators notified unitholders of the termination of the Shield Master Fund. A copy of the notice is available on the Liquidators’ website at: A&M website.
On 7 June 2025, ASIC cancelled the Australian Financial Services (AFS) licence of Financial Services Group Australia Pty Ltd (FSGA) and permanently banned FSGA’s Responsible Manager (RM) Graham Holmes (25-102MR). Certain authorised representatives of FSGA provided personal financial product advice to consumers to invest in the Shield Master Fund. Ferras Merhi was the sole director of FSGA from 10 February 2021 to 30 May 2025. ASIC is investigating Mr Merhi and various entities associated with him, in connection with its investigations concerning Shield and First Guardian. If you intend to lodge a complaint with AFCA in relation to advice received from FSGA or its authorised representatives you should do so by 4 June 2026.
On 17 June 2025, ASIC banned Queensland based former financial adviser Isaac Jacob McQueen, an authorised representative of MWL Financial Services Pty Ltd from 31 October 2022 to 9 June 2023, from providing financial services or controlling an entity that carries on a financial business, for 4 years (25-127MR).
On 3 July 2025, ASIC banned Matthew Simon Bradley, a Sydney based financial adviser, and authorised representative of MWL Financial Services Pty Ltd from 11 October 2017 to 27 December 2021 and from 28 March 2022, from providing financial services or controlling an entity that carries on a financial business, for 8 years (25-128MR).
On 18 July 2025, ASIC banned former MWL Financial Services advisers, Rocco D’Amelio, for 7 years and Robert Crossing for 6 years, from providing financial services, controlling an entity that carries on a financial services business or performing any function involved in the carrying on of a financial services business (25-146MR).
On 15 August 2025, the Receivers issued a Notice Calling for Proofs of Debt to Creditors advising that they have identified assets which may be distributed to qualifying unit holders of Shield, from property held by KAM in its capacity as responsible entity of Shield.
The Receivers intend to apply to the Court for authorisation to proceed with an interim distribution to qualifying unit holders. To facilitate this process, the Receivers are requesting that all creditors of KAM complete a formal proof of debt claim form and submit all supporting documentation by Friday, 5 September 2025.
This information will assist the Receivers in:
determining the amount of Shield property to be set aside and retained to pay entitled creditors, and
supporting the Receiver’s court application for interim payments to qualifying unit holders.
On 25 August 2025, ASIC cancelled the Australian Financial Services (AFS) licence of MWL Financial Services Pty Ltd and banned its director, Nicholas Maikousis, for 10 years for multiple compliance failures. ASIC found MWL operated a “low cost advice project” from 2021, using telemarketing referrals to recommend superannuation investments in Shield. Between September 2021 and February 2024, over 750 clients invested approximately $155 million. From 25 September 2025, Mr Maikousis is also banned from controlling or performing any function in a financial services business (25-180MR).
ASIC has banned Robert John Tohill, responsible manager and compliance manager of MWL Financial Services Pty Ltd (MWL), for 5 years from providing any financial services, performing, as an officer, responsible manager or compliance manager, any function involved in the carrying on of a financial services business and controlling an entity that carries on a financial services business. ASIC’s findings against Mr Tohill included that he failed in his gatekeeper functions as compliance manager and responsible manager (25-181MR).
On 26 August 2025, ASIC commenced civil proceedings against Equity Trustees alleging failures in due diligence concerning the Shield Master Fund (25-176MR). Equity Trustees oversaw the investment of around $160 million of retirement savings into Shield. ASIC alleges Equity Trustees contravened s52 and s54B of the Superannuation Industry (Supervision) Act 1993 (Cth) and s912A of the Corporations Act 2001 (Cth) by failing to:
exercise the same degree of care, skill and diligence as a prudent superannuation trustee;
act in the best interests of its members;
ensure financial services covered by its Australian financial services licence were provided efficiently, honestly and fairly.
Equity Trustees, as trustee for the AMG Superannuation Fund and Super Simplifier, approved the four classes of Shield as investment options on the NQ Super and Super Simplifier platforms.
ASIC is seeking declarations and civil penalties from the Federal Court.
On 29 August 2025, ASIC sought leave to expand the existing Federal Court civil proceedings against former financial adviser Ferras Merhi, alleging he engaged in unconscionable conduct, failed to act in clients’ best interests, gave conflicted advice, and issued defective statements of advice while receiving millions in fees (25-184MR). ASIC alleges Mr Merhi used marketing companies to direct clients to his advice businesses, Venture Egg and Financial Services Group Australia (in liquidation). Between 2020 and 2024, clients were advised to invest approximately $296 million into the First Guardian Master Fund and $230 million into the Shield Master Fund.
In return, Mr Merhi’s businesses allegedly received nearly $18 million in upfront advice fees and over $19 million in marketing payments from entities associated with First Guardian.
ASIC’s application to make these allegations is subject to the Court’s approval. If the Court gives approval, ASIC will seek interim injunctions prohibiting Mr Merhi from any involvement in a financial services business, the appointment of a receiver to Merhi’s personal property and provisional liquidators to Venture Egg and United Financial Advice.
Relevant media releases
ASIC has made interim stop orders on four product disclosure statements (PDSs) for classes of units of the Shield Master Fund (ARSN 650112057) (Fund), a registered managed fund promoted by KAM (24-018MR).
ASIC has obtained interim orders from the Federal Court freezing the assets of the Shield Master Fund (Shield), a registered managed fund whose responsible entity is KAM (24-129MR).
The Federal Court has appointed Jason Tracy and Lucica Palaghia of Deloitte to have full control of the bank accounts of the Shield Master Fund (Shield) (24-137MR).
On 27 August 2024, the Federal Court appointed Jason Tracy and Lucica Palaghia of Deloitte as receivers of the property of KAM.
On 5 September 2024, the Federal Court made orders appointing Mr Tracy and Ms Palaghia of Deloitte as voluntary administrators in addition to their role as receivers (Orders) (24-197MR).
ASIC notes the outcome of the second creditors’ meeting of KAM on 2 December 2024 at which creditors resolved to wind up KAM and appoint Jason Tracy and Glen Kanevsky of Deloitte as joint and several liquidators (24-265MR).
Following an application made by ASIC, the Federal Court has made interim orders freezing certain assets of Melbourne-based financial adviser Ferras Merhi.
Effective 31 May 2025, Mr Merhi and Venture Egg are no longer authorised representatives of Interprac Financial Planning Pty Ltd (25-024MR).
Following an application made by ASIC, the Federal Court has made interim orders freezing certain assets of Osama Saad, former director of Aus Super Compare Pty Ltd (in liquidation) and Atlas Marketing Pty Ltd (in liquidation) (25-023MR).
Following an application made by ASIC, the Federal Court has made orders freezing assets of Rashid Alshakshir, director of Lion & Horn Pty Ltd (in liquidation), Nohap Pty Ltd (in liquidation) and Indigo Group Pty Ltd (in liquidation) (25-043MR).
On 7 June 2025, ASIC cancelled the Australian Financial Services (AFS) licence of Financial Services Group Australia Pty Ltd (FSGA) and permanently banned FSGA’s Responsible Manager (RM) Graham Holmes.
Certain authorised representatives of FSGA provided personal financial product advice to consumers who invested the First Guardian Master Fund. Ferras Merhi was the sole director of FSGA from 10 February 2021 to 30 May 2025. ASIC is investigating Mr Merhi and various entities associated with him, in connection with its investigations concerning Shield and First Guardian. If you intend to lodge a complaint with AFCA in relation to advice received from FSGA or its authorised representatives you should do so by 4 June 2026 (25-102MR).
On 17 June 2025, ASIC banned Queensland based former financial adviser Isaac Jacob McQueen, an authorised representative of MWL Financial Services Pty Ltd, from providing financial services or controlling an entity that carries on a financial business for 4 years (25-127MR).
On 3 July 2025, ASIC banned Matthew Simon Bradley, a Sydney based financial adviser, and authorised representative of MWL Financial Services Pty Ltd, from providing financial services or controlling an entity that carries on a financial services business for 8 years (25-128MR).
On 18 July 2025, ASIC has banned the following former financial advisers of MWL Financial Services Pty Ltd (MWL) from providing financial services, controlling an entity that carries on a financial services business or performing any function involved in the carrying on of a financial services business:
Rocco D’Amelio for 7 years from 18 July 2025, and
Robert Crossing for 6 years from 18 July 2025 (25-146MR).
ASIC has commenced civil penalty proceedings in the Federal Court against Equity Trustees Superannuation Limited (Equity Trustees), alleging failures in due diligence concerning the Shield Master Fund (25-176MR).
On 25 August 2025, ASIC banned Robert John Tohill for a period of 5 years from providing any financial services, performing, as an officer, responsible manager or compliance manager, any function involved in the carrying on of a financial services business and controlling an entity that carries on a financial services business (25-180MR).
On 25 August 2025, ASIC cancelled the Australian Financial Services licence of MWL Financial Services Pty Ltd (MWL) and banned MWL’s director Nicholas Maikousis for 10 years from providing financial services or controlling an entity that carries on a financial services business or performing any function involved in the carrying on of a financial services business over conduct in relation to Shield.
ASIC found MWL operated what it called a “low cost advice project” from 2021 to receive referrals from telemarketers/lead generators and to recommend clients invest their superannuation in Shield.
If you intend to lodge a complaint with AFCA in relation to advice received from MWL or its authorised representatives you should do so by 25 August 2026 (25-181MR).
On 29 August 2025, ASIC sought leave from the Federal Court to expand its existing proceeding against former financial adviser Ferras Merhi to allege he engaged in unconscionable conduct, failed to act in the best interests of clients, gave conflicted advice, and provided defective statements of advice whilst receiving millions of dollars (25-184MR).