Anti-money Laundering

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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 would like further information on how Thistle can help you, please contact us on 0207 436 0630  or email us on

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