ASIC has commenced civil penalty proceedings against former financial adviser Osama Saad, alleging he carried out schemes to avoid conflicted remuneration laws and contravened his best interest obligations when providing financial advice to hundreds of clients to invest their superannuation into the First Guardian Master Fund (First Guardian), which later collapsed.

ASIC alleges Mr Saad's entities, Atlas Marketing and United Capital, were paid around $34 million by entities connected to the Shield Master Fund (Shield) and First Guardian.

ASIC alleges some of the money was used for Mr Saad's personal benefit and for the benefit of individuals and entities associated with him.

ASIC also alleges some of the monies funded marketing and lead generation entities which referred thousands of clients to Venture Egg and Financial Services Group Australia. Those firms recommended clients invest their superannuation into Shield, First Guardian, or both.

ASIC Chair Sarah Court said, 'Conflicted remuneration laws are there to protect consumers by banning payments and other benefits that could influence the advice they receive, or the financial products recommended to them.

'We allege Mr Saad participated in schemes to avoid these laws, and his companies were paid tens of millions of dollars by entities linked to First Guardian and Shield,’ the Chair said.

ASIC further alleges that between February and December 2021, Mr Saad advised 217 retail clients to roll over more than $25 million of their superannuation into First Guardian.

ASIC alleges the advice was not in the clients' best interests, was inappropriate, and that Mr Saad prioritised his own interests over his clients’ interests.

‘We allege Mr Saad steered the retirement savings of hundreds of Australians into high-risk investments that later collapsed, without regard for the clients’ financial circumstances or needs.

‘Australians expect, and the law requires, financial advisers to act in their clients' best interests when making decisions about their retirement savings. We allege that did not happen here,’ the Chair said.

ASIC is seeking declarations, pecuniary penalties, orders restraining Mr Saad from providing financial services and disqualification from managing corporations.

The action against Mr Saad forms part of ASIC’s 2026 enforcement priority to hold to account those responsible for the collapse of First Guardian and Shield.

The ongoing investigations are among the largest and most complex ever undertaken by ASIC.

‘We have now commenced 17 proceedings in connection with our ongoing investigations, and we expect to take further action,’ the Chair said.

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Originating Process

Concise Statement

Background

Mr Saad was an authorised representative of Interprac Financial Planning between 17 June 2016 and 31 December 2021 and provided financial advice to retail investors through Venture Egg.

In February 2025, following an application by ASIC, the Federal Court made interim orders freezing certain assets of Mr Saad (25-023MR).

ASIC’s Regulatory Guide 246 Conflicted and other banned remuneration (RG 246) sets out guidance on complying with the conflicted and other banned remuneration provisions in Divisions 4 and 5 of Part 7.7A of the Corporations Act. 

Consumer information

ASIC has issued a consumer alert warning amid increasing concerns that people are being enticed to invest their retirement savings into complex and risky schemes (25-120MR Consumer alert). Be super smart, visit ASIC’s Moneysmart campaign page.

Stay Updated: ASIC will post important updates on its dedicated webpages: Shield Master Fund and the First Guardian Master Fund.

Insurance

You should also contact your super fund to ask if you have insurance, to check whether premiums continue to be deducted from your superannuation account and to consider the suitability of your current insurance arrangements: Insurance through super - Moneysmart.gov.au

Under the law, super funds will cancel insurance on inactive super accounts that haven’t received contributions for at least 16 months if the member has not made an election to keep their insurance. In addition, super funds may have their own rules that require the cancellation of insurance on super accounts in other circumstances, such as where balances are too low.

Your super fund will generally contact you if your insurance is about to end. You should make sure your super fund has your current contact details.

If you want to keep your insurance, but your account may be affected by the issues described above, you’ll need to tell your super fund or contribute to that super account.

You may want to keep your insurance if you:

• don't have insurance through another super fund or insurer
• have a particular need for it, for example, you have children or dependants, or work in a high-risk job

If you are unsure about the suitability of your current insurance arrangements, you should seek personal advice from a registered financial adviser. ASIC’s Moneysmart website has information on how to choose a financial adviser.