I think your right Aaron, we are in the process of working with Dukascopy on this, and have been in contact with their legal team, as we are in the process of setting up a small prop trader firm, and there are certain things you can do, unlicensed, that do not fit the description/terms of the AFSL requirements.
I've just gone through all of the definitions and information I could find on PAMM and MAMM accounts, and a heap of legislation and previous cases, and in essence, what we will be doing is defined as the following:
> Providing a signal or signals for educational purposes
> Providing educational services
What you cannot do is:
> Advise on placing or closing particular trades
> Advise on and/or suggest investments
> Entice/canvas (directly) for clients, especially as 'providing investment solutions'.
> Make false claims or any claims or promises in relation to ROI
What we can do is:
> Run workshops for educational purposes
> Advertise/display our trading results/accounts on-line, and allow the client to freely choose or access our account signals PAMM, MAMM, subscription services etc, from a list of others
> Offer educational material in relation to the markets (with disclaimer)
> Charge for workshops etc
> Offer free information sessions
> Sell indicators and signals (these are not financial products)!
> Run PAMM and MAMM accounts overseas and potentially in AUS via signal based arrangement/s.
> Sell subscriptions via Signal providers and also Myfxbook
This would appear to be the way that the brokerage and publications houses, in addition to those selling EA's, trading bots, indicators and signals on MQL sites etc, get around this.