The Client
- Specialists in litigation funding focused on complex, high-value disputes
- Not yet regulated by the Financial Conduct Authority (FCA)
The Challenge
The client, a non-bank financial institution, had ambitious plans to expand its client portfolio. To achieve this, they required the immediate implementation of a scalable, expert-led approach to Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures.
The client aimed to build a solid financial crime framework; however, they lacked an internal KYC team capable of managing this growth, with the financial crime expertise needed to onboard complex international corporate clients.
The Solution
Thistle Initiatives' support was divided into two phases.
In Phase 1, Thistle SMEs designed a financial crime framework that included:
- An AML/CTF Policy;
- A Customer Due Diligence (CDD) Procedure; and
- A Customer Risk Assessment methodology and workbook.
These documents were specifically tailored to align with the firm’s unique business model, risk profile, and investment processes, ensuring rigorous yet practical compliance.
Thistle Initiatives also created an AML onboarding form, an outreach template for contacting potential clients, and a one-page report template to help the firm evaluate the feasibility, risks and red flags associated with each deal, enabling informed decision-making at the Investment Committee.
In Phase 2, which is currently ongoing, we have deployed expert resources to undertake the firm's due diligence processes for onboarding new clients.
We respond to new client requests within one business day, sending the AML onboarding form to potential investors and managing the outreach process alongside the initial review of their responses. Our team conducts due diligence on complex international corporates, navigating challenging structures to identify ultimate beneficial owners (UBOs) and maintaining communication with investors.
For high-risk cases, we perform Enhanced Due Diligence (EDD) and request additional information and supporting documentation. We also risk-assess the investors and prepare a KYC pack for the firm to determine whether to proceed with onboarding the client or not.
The Result
Thistle Initiatives effectively supported the firm in building an AML framework focused on the due diligence measures necessary to onboard new clients and expand the firm’s portfolio.
By outsourcing the due diligence process to Thistle, the client can focus on core business activities, confident that financial crime risks are mitigated and the onboarding process aligns with FCA standards and expectations.
Our Financial Crime Team
Thistle Initiatives’ Financial Crime team combines regulatory expertise with practical experience across the financial services sector. We deliver proportionate, risk-based solutions that balance compliance with commercial needs, helping firms strengthen AML, CTF, sanctions, and anti-bribery controls.
Our specialists are recognised for delivering high-quality, pragmatic support that enhances both compliance standards and operational efficiency. Get in touch with us by calling 020 7436 0630 or sending an email to info@thistleinitiatives.co.uk.
Meet the Expert
Ilaria Iodice, Senior Manager 
Ilaria has a deep understanding of Financial Crime Compliance and has offered valuable support to various organisations, including Tier 1 Banks across the UK, EU, and internationally.
Her expertise includes conducting Quality Control assessments to identify areas for enhancement and overseeing FCC programs to devise strategies for implementing robust internal controls. Experienced in leading diverse teams, both onshore and offshore, Ilaria has managed large-scale, complex projects across multiple jurisdictions, ensuring seamless execution and regulatory adherence.
Prior to Thistle, she gained significant experience at various consultancy firms, including a Big4 firm, and contributed to the global monitorship involving HSBC. Ilaria holds an L.L.M and L.L.B in Law.