Thistle had a face to face meeting with the client, gathering information through discussions and document sharing, specifically around their model, current operations and key milestones, followed by a gap analysis of the information and documentation provided. The focus was on their current AML & KYC processes, as well as their customer journey.
Following the gap analysis, we issued a report highlighting our initial findings and where improvements could be made, setting out expectations, as well as proposing a project plan with implementation dates.
Using the information gathered and the targets agreed post our report, financial crime policies and KYC due diligence procedural documents were produced, with feedback on where development was needed and the likely time forecast as part of the implementation. This also included a risk assessment which the firm is now able to maintain internally, updating it with any changes in model or process. Thistle also assisted the client make relevant disclosures on their website to ensure investors understand the risks associated.