Compliance Solutions

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Thistle Initiatives offer a comprehensive range of compliance solutions – both from a strategic planning and an implementation perspective.

A starting point can often be a simple health check where we can assess your needs and the key areas that you need to address. This could be part of a broad strategy as wide ranging as helping you to manage your overall compliance solution or a very specific tailored solution to a particular issue.

Such solutions could be as focused as undertaking an audit of your existing compliance resource”) or offering detailed advice on a particular technical aspect of the FCA’s rules and regulations.

We aim to build up a detailed understanding of our client’s business model enabling us to be proactive in our approach. We look to add value to your firm; this means as a specialist we aim to use our knowledge and experience to help you to manage your firm in a compliant manner and where possible save you time and money..

Thistle advises a wide range of clients including financial advisers, insurance intermediaries, stock/derivative brokers, corporate finance and Unregulated Collective Investment Schemes (UCIS) distributors.


    Although your firm may be directly authorised and you have responsibility for your compliance function it is often helpful to speak to an outside expert. The field of financial services regulation is rapidly evolving and Thistle will ensure that you are kept in touch with the latest developments and their possible impact on your firm.

    Many of our clients find it invaluable to talk to Thistle Initiatives for input and advice on everything from strategic planning to helping with compliance training. Whether it’s a simple sense check or advice on a specific compliance issue – our skilled and experienced staff will be able to help add value to your business, when and where you need it. We are happy to work on either a retainer basis or to advise on a particular issue for a one off fee.

    Our Financial Services team provides advice to a large number of FCA regulated clients, including securities and futures firms, banks, investment management firms, financial advisers and insurance intermediaries.

    Thistle Initiatives can assist with providing technical advice in respect of the following:

    FCA Applications FCA Rules and Regulations Compliance Monitoring Plans FCA Compliance Health Checks Risks Assessments (Including ICAAP, Liquidity Reporting and Stress Testing) FCA Enforcement Action (Including Skilled Persons Reports) Training & Competence Suitability Assessments

    If you are interested in our audit services and would like some more information about what Thistle Initiatives can offer your business, contact us on 020 7436 0630.


    Regulated firms’ anti-money laundering arrangements remain a high priority for both the Financial Conduct Authority and overseas regulatory bodies. At Thistle Initiatives we have a wealth of experience within this area and can help to ensure that firms are addressing the issues properly.

    All firms that are subject to the Money Laundering Regulations (2007) must put into place systems and controls in order to assist in the prevention and detection of money laundering, the process by which the proceeds of crime are converted into assets which appear to have a legitimate origin.

    At Thistle Initiatives we understand that firms are required to implement systems and controls in order to identify, assess and monitor both money laundering risk and suspicious transactions. In addition customer due diligence (CDD) measures and monitoring must be in place to manage the risks identified. Under the Proceeds of Crime Act 2002, a Suspicious Activity Report must be submitted to the Serious Organised Crime Agency (SOCA) where it is known or suspected that a person is engaged in, or attempting, money laundering.

    All firms that are subject to the FCA’s AML rules must allocate overall responsibility for AML systems and controls to a director or senior manager. They must also appoint a UK-based Money Laundering Reporting Officer (MLRO) to act as a focal point for the firm’s anti-money laundering activity.

    We work with firms to ensure that they are able to demonstrate to the FCA that the appropriate CDD measures and procedures are in place and adhered to.

    Thistle Initiatives can offer a range of services in relation to anti-money laundering procedures, including a review of risk assessment and CDD arrangements or Suspicious Activity Reporting and a review of the MLRO’s annual report.

    If you are interested in our audit services and would like some more information about what Thistle Initiatives can offer your business, contact us on 020 7436 0630.


    An essential part of the FCA’s expectations of  a firm’s systems and controls, according to the Senior Management Arrangements, Systems and Controls (SYSC) sourcebook, is to have compliance documentation and manuals as part of an overall system of control. If a firm fails to have the relevant documentation available then they can risk having a non-compliant nature.

    From our experience, we have found that many firms do not have these fundamental manuals in place, despite believing their business is compliant. Thistle Initiatives have assisted many firms in upholding a fully compliant culture within their regulated business activities.

    From creating bespoke procedures for our clients and their specific business activities, or helping to implement simple compliance manuals for firms of all sizes, whatever the issue, we work closely with our clients to ensure they achieve the compliant results they desire.

    If you are interested in speaking to one of Thistle Initiatives experts for a no obligation  assessment of your compliance manuals, contact us on 020 7436 0630.


    FCA regulated firms need to satisfy Capital Adequacy requirements however, understanding the relevant rules and regulations can be time-consuming and extremely complex.

    At Thistle Initiatives we have a team of experts who can assist you in understanding and fulfilling your regulatory obligations. Whether you are an investment bank, a fund manager or an insurer we can assist.

    We also have vast experience in preparing ICAAPs and ILAA.

    ICAAP

    The purpose of the Internal Capital Adequacy Assessment Process (ICAAP) document is to keep the firm’s Board informed of the ongoing assessment of the firm’s risks, how the firm intends to mitigate those risks and how much current and future capital is necessary having considered other mitigating factors. The ICAAP document is also used by the firm to outline to the FCA or the Prudential Regulation Authority (PRA) its internal capital adequacy assessment process.

    ILAA

    The aim of the Individual Liquidity Adequacy Assessment (ILAA) is to help firms ensure they meet the overall liquidity adequacy rule and to enable the FCA or PRA to assess firms’ liquidity more effectively. It is a key tool for demonstrating appropriate liquidity risk management.

    If you are interested in speaking to one of Thistle Initiatives experts for a no obligation  assessment of your compliance manuals, contact us on 020 7436 0630.


    Simply having the correct systems and controls in place is not enough to prove to the FCA that your firm is compliant. Your firm needs to provide clear and documented evidence that a culture of compliance is embodied within every significant decision making process, particularly with regards to your customers. The introduction of the FCA has seen the focus on this area increase significantly. We can help guide you through the considerations that are regarded as material and evidence the process.

    Thistle Initiatives understand that compliance is more than just ticking boxes. We can advise and help with the more holistic elements of compliance and work with companies to ensure the “compliance culture” is communicated throughout the business.

    To assist its clients Thistle Initiatives provides a range of compliance monitoring services to ensure a firm remains compliant. These monitoring services include quality assurance, compliance understanding training and suitability. We can also give valuable insight and guidance into the way a remedial project is being managed to ensure these stay on track.

    We can provide “off the shelf” compliance monitoring solutions or work with the company to design and develop bespoke, tailored monitoring plans.

    If you are interested in speaking to one of Thistle Initiatives experts for a no obligation  assessment of your compliance manuals, contact us on 020 7436 0630.


    Many firms are faced with the challenge of understanding a wide variety of products which may be suitable for their clients. This is particularly the case in the investment sector where potentially high returns are linked to high risks and a large degree of volatility as well as counterparty uncertainty. It is an area where there is significant regulatory activity and this needs to be understood and conformed with.

    Thistle Initiatives can assist with conducting due diligence on counterparties to ensure compliance with FCA standards, whether this is as an operator of funds or SIPPs, or directly as an investor. Given the recent disasters including several failures of structured products and highly speculative geared investments, effective due diligence has never been so important.

    How we carry out due diligence

    Thistle Initiatives uses its highly experienced and skilled team to undertake assessments on investments. We will then provide an in-depth report into all aspects of the investment and its counter-parties.

    Thistle has undertaken extensive due diligence on investments such as:

    • Carbon Credits
    • Property Developments
    • Forestry Investments
    • Unregulated companies
    • Storage Pods
    • Fuel Investments
    • Solar Power wind farms

    If you are interested in speaking to one of Thistle Initiatives experts for a no obligation  assessment of your compliance manuals, contact us on 020 7436 0630.

    All FCA regulated firms are required to demonstrate that their staff are competent to perform their role. Devising a process which enables the assessment of staff competence, identification of training needs and then implementation of the required courses/training to ensure that staff are up to speed is crucially important. A key area of business for Thistle initiatives is in the provision of training and assessing staff.

    Thistle Initiatives offers on and offsite training, at both a senior and junior level. We can assess staff, recommend who needs training and the level of training required to meet required competence levels. We can plan and arrange courses or ongoing training and have run successful “train the trainer” schemes in a number of large financial organisations.

    Whilst minimum standards of performance will be required before an individual can carry out their role, competence does not have to be achieved prior to undertaking the activity as long as appropriate supervision is in place. However, once an individual is assessed as competent the level and intensity of supervision can become significantly lower.

    Thistle are able to put in place clear criteria and procedures for both achieving and maintaining competence.

    If you are interested in speaking to one of Thistle Initiatives experts for a no obligation assessment of your compliance manuals, contact us on 020 7436 0630.

    If you would like further information on how Thistle can help you, please contact us on 020 7866 2132 or email us on info@thistleinitiatives.co.uk

    Thistle FCA Enforcement Support