
Financial Crime
Financial crime compliance is under intense regulatory scrutiny. At Thistle Initiatives, we help firms act swiftly and respond with confidence.
Our experts deliver audits, advisory, and managed resources that are fast, practical, and effective. With former regulators and industry specialists on our team, we bring experience from multiple sectors and major enforcement programmes. We combine deep regulatory expertise with commercial insight, tailoring solutions to each client’s business model, risk profile and maturity.
We’re here to solve complex financial crime challenges and keep your operations moving.
Jessica Cath
Managing Partner
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Financial crime compliance is under intense regulatory scrutiny. At Thistle Initiatives, we help firms act swiftly and respond with confidence.
Our experts deliver audits, advisory, and managed resources that are fast, practical, and effective. With former regulators and industry specialists on our team, we bring experience from multiple sectors and major enforcement programmes. We combine deep regulatory expertise with commercial insight, tailoring solutions to each client’s business model, risk profile and maturity.
We’re here to solve complex financial crime challenges and keep your operations moving.
Jessica Cath
Partner, Financial Crime
Financial Crime solutions tailored to you
Our consulting services are designed to support firms in navigating complex financial crime risks and regulatory demands. We offer a full spectrum of audit, advisory, and people-based solutions tailored to meet your specific needs.
Audit
We conduct robust financial crime audits, health checks and skilled person reviews to assess the effectiveness of your current controls and identify areas for improvement. Our audits audits provide independent evaluations aligned with regulatory expectations.
Our team also provides specialist
assurance and systems testing, looking at individual controls or specific tools.
We help ensure your processes and
technologies are both effective and
compliant.
We cover:
• Audits and health checks
• Skilled person reviews
• Specialist assurance
• Systems testing
Advisory
Our advisory team works closely with clients to enhance financial crime frameworks, from short and targeted advice on specific problems or full scale remediation.
We assist in developing or refining financial crime documentation, aligning with industry best practice and regulatory requirements. We also drive operational enhancements that streamline compliance efforts and reduce risk exposure.
We cover:
• Policy, procedures and risk assessments
• Operational enhancements
• Technology implementation
• Regulatory enforcement support and remediation
• Training and MLRO hotline
People
We offer flexible access to skilled financial crime professionals who can seamlessly integrate into your teams during peak times or major projects. Our specialists can tackle file remediations and backlogs efficiently, ensuring records are complete and regulatory standards are met.
By combining deep regulatory expertise with practical experience, our consultants help you plug immediate resource needs and build resilient financial crime programmes that can adapt to evolving threats and obligations. Whether you need a short-term project team or long-term strategic support, we’re here to help safeguard your business.
We cover:
• Flexible financial crime resources
• File remediations and backlogs
• Outsourced corporate onboarding
We can support you in these areas of legislation and guidance
Anti-Money Laundering
A strong commitment to preventing money laundering is essential for any financial institution. Firms must implement a robust AML framework supported by clear oversight and effective controls. This framework should align with Money Laundering Regulations and guidance, as well as global standards from the Financial Action Taskforce (FATF) and guidance from bodies such as the Wolfsberg Group. Our approach is informed by a deep understanding of regulatory frameworks and guidance, tailored to the specific risk profile and operating environment of each organisation.
Anti-Bribery, Corruption, and Facilitation of Tax Evasion
Firms must take proactive measures to prevent bribery, corruption, and the facilitation of tax evasion, all of which carry significant legal and reputational risks. We help firms establish and embed clear frameworks, implement proportionate controls, and foster a culture of transparency and accountability. Our advisory services include policy development, risk assessment, and third-party due diligence support, as well as investigations.
Sanctions Compliance
Global sanctions regimes are complex, fast-changing and present particularly high risks. To comply, firms must maintain up-to-date sanctions screening systems and respond quickly to regulatory updates. We assist clients in navigating these challenges by designing and testing effective sanctions compliance programmes. This includes implementing screening tools, enhancing governance and reporting structures, and ensuring staff are trained to identify and manage potential sanctions risks.
Read moreCounter‑Terrorist Financing and Counter‑Proliferation Financing
Firms are obligated to prevent the misuse of financial systems for the funding of terrorism and the proliferation of weapons of mass destruction. A comprehensive risk-based framework should be in place to detect, monitor, and report any suspicious activity. We help firms safeguard against the risks of terrorist financing and the funding of weapons proliferation through tailored risk assessments, targeted controls, and robust due diligence practices. Our services support organisations in meeting international obligations while effectively managing operational impact.
Fraud Prevention
Fraud involves the use of deception to secure unlawful gain and is a persistent threat across sectors. To combat fraud, firms should implement strong internal controls such as fraud monitoring, staff awareness initiatives, and incident response plans. We work with clients to assess vulnerabilities, and build a proactive fraud risk management strategy. This includes policies and procedures, risk assessments, staff training, investigative support, and the integration of fraud prevention into broader compliance frameworks.
Read moreAre you Ready for Failure to Prevent Fraud?
With the offence now in force as of 1st September 2025, we’ve developed a short self-assessment tool to help you understand how prepared your firm really is.
It takes just five minutes to complete and provides an instant summary of your results, highlighting any potential gaps across key areas like governance, risk assessment, due diligence and training. You’ll also have the option to speak with a member of the Thistle Initiatives team about your findings and next steps.
What our clients have to say
The on-site visits and meetings were an efficient and effective way for the firm’s employees to demonstrate their knowledge and experience of AML, and AML Risks, and the one-to-one File reviews enabled both parties to complete the process and gain insights from the review teams experience.
Other all, I found the Thistle review team to be very knowledgeable, and I would have no hesitation in recommending them or using them again in the future.”
Challenge
The Firm faced regulatory scrutiny and had started to build a remediation plan, but did not have the internal capacity or expertise to deliver on the plan.
How we helped
Thistle provided expert advisory support to draft a full remediation plan, with clear ownership, actions, dates and tracking.
We provided a senior, expert advisor to set up weekly governance forums and work alongside the MLRO to drive the remediation plan forward. This expert advisor also supported with communication to the regulator.
We worked with the Firm to split remediation tasks, with Thistle addressing particularly challenging areas such as full policy and procedure uplift for onboarding and ongoing monitoring, as well as the rebuild of customer risk assessment methodologies in the internal, automated tooling. Thistle flexed the remediation team up and down throughout the course of the programme to ensure cost effective delivery within short timescales.
Thistle also provided a team of 10 analyst resources to work through a backlog of sanctions screening alerts, which were placed on site within two days.
Outcome
Extensive remediation has been undertaken effectively and in a short period of time, without impacting BAU operations. Improvements have been made to all financial crime policies and procedures, risk assessments, customer journeys and tooling, as well as the provision of resource support to BAU teams to clear backlogs quickly. The Firm avoided a formal regulatory review and all restrictions were lifted.
Challenge
The client had ambitious plans to expand its client portfolio and required an immediate implementation of a scalable, expert-led approach to Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures.
How we helped
Thistle Initiatives designed an SME financial crime network that included an AML/CTF policy, a Customer Due Diligence (CDD) procedure, and a Customer Risk Assessment methodology workbook documentation specifically tailored to align with the client firm’s unique business model.
We developed an AML onboarding form, an outreach template for contacting potential clients, and a one-page report template to help make the evaluation feasible with considerations to risks and red flags associated with each deal to enable informed decision-making at the Investment Committee.
There is also an ongoing expert resource to undertake the firm’s due diligence processes for onboarding new clients.
We ensured a swift response to new client requests within one business day, sending the AML onboarding form to potential investors, and managed the outreach process along with the initial review of responses. Thistle conducts due diligence on complex international corporates to navigate challenging structures in identifying ultimate beneficial owners and maintain communication with investors.
We performed Enhanced Due Diligence (EDD) for high-risk cases that required additional information and supporting documentation. Thistle also conducted a risk assessment of the investors and prepared a KYC pack to determine client onboarding.
Outcome
Thistle Initiatives supported the firm in building an AML framework that focused on due diligence measures for onboarding new clients and expanding the client’s portfolio.
Outsourcing the due diligence process to Thistle enabled the client to focus on core business activities with confidence that financial crime risks are mitigated and onboarding processes align with FCA standards.
Do you need expert compliance support, fast?
When deadlines are tight and the stakes are high, our Managed Services team delivers. We’ve deployed 15 analysts in just one business day, clearing 20,000+ sanctions and PEP cases in under three weeks.
From KYC and CDD to AML investigations, sanctions screening, and remediation projects, our experts integrate seamlessly into your operations, tackling backlogs, meeting FCA expectations, and keeping your business moving.
Why Thistle Initiatives?
Our expert consultants
Our subject matter expertise
Our team of experts understands the intricacies and nuances of financial crime compliance. Our Senior Team have served on some of the largest global monitorships and Skilled Person Reviews.
Our strong track record
We have a strong track record of supporting companies in remediating their processes, procedures, and financial crime frameworks. We have played a crucial role in assisting organisations during periods of transformation, helping to ensure that they meet regulatory requirements and enhance their operational effectiveness.
Client-focused delivery
Our managed resources
Rapid financial crime response
Flexible specialists
Solve critical backlogs
More from the industry
Your points of contact
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Jessica Cath

Managing Partner
Jessica is a financial crime leader, working with a range of firms to build, scale and assure all elements of the financial crime framework. She has worked with start-ups to Tier 1 Banks to transform controls through growth phases or when facing regulatory enforcement.
Jess has also conducted multiple US monitor and s166 Skilled Person reviews globally, and has a Masters Degree in Intelligence and International Security and holds an ICA diploma in Financial Crime Prevention.

Michael Knight-Robson

Partner, Financial Crime
Michael Knight-Robson has joined as a Partner in the Financial Crime team, working alongside Jessica Cath. With over 15 years’ experience in financial crime compliance, he was most recently a Director at BDO, where he built a strong reputation for leading s166 Skilled Person reviews and providing firms with proportionate, risk-based advice to stay compliant.
His career also includes senior roles at Bovill, Lloyds Banking Group and Investec, giving him practical, well-rounded expertise to help firms strengthen their financial crime compliance frameworks.
Leanda has over 14 years financial crime experience, including in the banking industry and at the FCA, and has completed the CAMs certification, ICA Financial Crime Prevention Diploma and ICA Anti-corruption certificate. Leanda has extensive expertise in both AML and ABC, building and assuring frameworks.








'''Working with Thistle Initiatives has been an amazing experience.
Their team is professional, organised, supportive and highly knowledgeable in Financial Crime. Moreover, their approach to stakeholder management and communication within our organisation has been perfect at all stages.
Thistle conducted our annual AML Audit, and their methodology, scope, and execution were carefully structured and well-timed. The advice provided to our organisation was incredibly helpful. We look forward to collaborating with the Thistle team again soon."