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Financial Crime

The financial crime obligations placed on financial services firms are ever evolving and becoming ever more stringent.

In 2017 alone, the Fourth Money Laundering Directive (4MLD) was transposed into UK legislation, the Criminal Finances Act 2017 came into force and the Joint Money Laundering Steering Group (JMLSG) guidance was revised, all of which placed increased requirements on businesses. Firms run the risk of being fined or reprimanded if they fail to implement financial crime prevention processes in line with the new regulations.

Thistle’s Financial Crime team are experts in assisting firms with their anti-money laundering and counter-terrorist financing risk and policy framework, as well as providing compliance advice, reports, audits, training and on-site support where necessary.

The Financial Crime team assist firms in the following areas:

Anti-Money Laundering & Terrorist Financing – Thistle helps firms implement proportionate and risk-based policies and procedures to comply with the Money Laundering Regulations 2017, the FCA Handbook and industry guidance. Our assistance includes helping firms to conduct an AML risk assessment on its business operations, reviewing customer due diligence arrangements and offering guidance on firm’s AML governance.

Anti-Money Laundering Auditing – Anti-money laundering audits provide an important review of a firms controls to ensure all systems, procedures and assessments exist, are effective and meet or exceed what a firm should be doing, as per the obligations under the Money Laundering Regulations 2017. The results of such an AML report can assist a firm to understand where there may be any weaknesses within the firm’s financial crime framework and provide tailored feedback where the firm has implemented strong and proportionate controls, ultimately reassuring the business, its clients and its banking partner(s) of its abilities to mitigate money laundering risks. Thistle performs independent AML auditing of firms, including a review of written AML/CFT policies and procedures, business/client risk assessments and training programs. We will also work with firms to prioritise the specific actions that must be carried out in order to remediate any weaknesses identified from our AML audit report.

Bribery & Corruption – The Bribery Act 2010 and subsequent guidance issued by the Ministry of Justice requires firms to have adequate procedures in place to prevent bribery. Thistle assists firms in developing and implementing proportionate anti-bribery and corruption policies and procedures, as well as appropriate controls such as gift and hospitality registers.

Fraud – Fraud costs the UK economy approximately £193 billion per year. The private sector, both SMEs and large enterprises, are under the biggest attack from fraudsters, with far too many firms having inadequate procedures to effectively mitigate fraud risk. Thistle can help firms implement strong fraud policies and procedures to mitigate any fraud risks to which they might be vulnerable.

Tax Evasion – The introduction of the Criminal Finances Act 2017 placed obligations on firms to implement controls to prevent employees and associated parties facilitating tax evasion, in the UK or overseas. Thistle offers guidance to firms so they understand their requirements under the legislation, in addition to supporting them create a risk-based approach to tax evasion prevention based on industry guidance.

The Financial Crime team at Thistle are highly knowledgeable in all areas of financial crime regulation and the implications these regulations have on a wide range of financial services firms. We use our detailed knowledge of regulation, industry best practice and guidance to offer practical and tailored compliance solutions to your firm.

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