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Banking is undergoing a period of sustained structural change, and the pace and scale continue to accelerate.

From digital disruption and evolving customer expectations, to increasing regulatory pressure and cost challenges, firms must transform at pace without compromising resilience, compliance or customer outcomes.

At Thistle, we help banks, building societies and credit unions navigate this complexity with confidence.

Sam Coe
Partner

Sam Coe website rounded

Banking is undergoing a period of sustained structural change, and the pace and scale continue to accelerate.

From digital disruption and evolving customer expectations, to increasing regulatory pressure and cost challenges, firms must transform at pace without compromising resilience, compliance or customer outcomes.

At Thistle, we help banks, building societies and credit unions navigate this complexity with confidence.

Sam Coe
Partner

1000+

Successful FCA applications

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Winner of Best Financial Services Compliance Consultancy 2020 - 2024

2000+

Happy customers served

End‑to‑End Banking Change and Transformation Services

Thistle supports banks, building societies and credit unions as they navigate a rapidly evolving banking landscape. Whether delivering business or digital transformation, or responding to increasing regulatory pressure, we provide clear, practical support with a strong focus on delivery.

Transformation & Operating Model Design

We help banks, building societies and credit unions design and implement target operating models that are scalable, efficient and aligned to regulatory expectations.

Our approach combines strategic design with hands-on delivery, ensuring that operating models are not only defined but successfully embedded across the organisation. 

Our support includes:

  • Target Operating Model (TOM) design (Retail, Commercial, Wealth)

  • Organisational design and governance structures

  • Process optimisation and simplification

  • Cost reduction and efficiency programmes

  • Post-merger integration and separation 

Digital & Customer Transformation

We support banks, building societies and credit unions in delivering customer-centric transformation programmes that improve experience, increase engagement and drive measurable improvements in NPS and retention. 

We focus on aligning digital capability with human interaction ensuring the right balance of automation and personalisation. 

Our support includes:

  • Customer journey redesign (end-to-end)

  • Channel strategy (digital vs assisted)

  • Frontline enablement and tooling

  • Customer insight and feedback loops

  • Embedding customer-centric culture and incentives 

Regulatory Change & Compliance Transformation

We support banks, building societies and credit unions in responding to evolving regulatory requirements and embedding sustainable compliance frameworks. 

Our strength lies in translating regulation into practical, operational change. 

Our support includes:

  • Banking Licence Applications

  • Consumer Duty implementation and embedding

  • Operational Resilience and DORA readiness

  • Governance, risk and control frameworks

  • Regulatory remediation programmes

  • Skilled person review support and response

Technology & Platform Enablement

We help banks, building societies and credit unions modernise their technology landscape and deliver complex platform transformations.

We bring experience across vendor selection, implementation and integration, ensuring technology delivers real business value. 

Our support includes:

  • Platform strategy (Build vs Buy) 

  • Core banking and digital platform implementation 

  • Vendor selection and RFP support 

  • Data and reporting transformation 

  • Integration and migration planning 

Change Delivery & Programme Execution

We provide experienced delivery leadership and teams to drive complex transformation programmes from mobilisation through to execution.

We focus on delivery certainty, governance and pace, ensuring programmes stay on track and deliver outcomes. 

Our support includes:

  • Programme and portfolio management 

  • PMO design and mobilisation 

  • RAID, governance and reporting frameworks 

  • Benefits realisation and tracking 

  • Delivery assurance and recovery 

Embedding Change & Driving Adoption

A key differentiator for Thistle is our focus on making change stick.

We ensure that transformation is fully embedded across the organisation through structured change, communication and behavioural alignment. 

Our support includes:

  • Change management and communications 

  • Training and capability development 

  • Incentive design aligned to customer outcomes 

  • Cultural transformation programmes 

  • Post-implementation optimisation 

Want to learn more about our change and transformation expertise? Read more here.

Specialist Banking Compliance Support

Thistle has a long history of helping banking firms navigate complex regulatory requirements. From FCA and PRA authorisations, through supervision and enforcement, to ongoing compliance support, we work alongside firms to help them stay compliant as they grow and evolve.

FCA and PRA Authorisations FCA and PRA Authorisations

FCA and PRA Authorisations

We support firms through ongoing FCA and PRA supervision, helping them manage regulatory engagement clearly and confidently. 

Supervision and Enforcement Supervision and Enforcement

Supervision and Enforcement

We support firms through ongoing FCA and PRA supervision, helping them manage regulatory engagement clearly and confidently. 

Financial Crime Financial Crime

Financial Crime

A practical approach to AML, sanctions and fraud frameworks that meet regulatory expectations and reflect real‑world risk. 

Skilled Person Reviews Skilled Person Reviews

Skilled Person Reviews

Thistle Initiatives is delighted to have been appointed to the PRA and FCA Skilled Person Panel, strengthening our credentials to deliver effective remediation. 

ICARA and FCA Reporting ICARA and FCA Reporting

ICAAP and FCA Reporting

We support the sector meet the regulatory requirements around capital and liquidity, including ICAAP and regulatory reporting. 

Compliance Audits Compliance Audits

Compliance Audits

We deliver independent compliance reviews that identify gaps, strengthen controls and help firms prepare for FCA and PRA scrutiny.

Our Banking Expertise
Across Sectors

Our team supports banks, building societies and credit unions across the full spectrum of banking activity, including M&A, transformation and regulatory change.

 

  • Banks
  • Building Societies
  • Credit Unions
We’ve found Thistle to be an excellent partner. Their team combines deep technical knowledge with a pragmatic, commercial approach, which makes their advice genuinely useful at both board and operational level.
James Twining, CEO, Wren Sterling

Financial Crime Prevention
in Banking

Financial crime controls that stand up to regulatory scrutiny and real‑world banking risk.

 

Financial crime compliance is a core part of running a safe, resilient bank. As products, channels and customer behaviours evolve, firms must ensure their AML, sanctions and fraud frameworks remain proportionate, effective and embedded in day‑to‑day operations. Weaknesses can quickly lead to supervisory action, remediation and constraints on growth.


  • Design, review and enhancement of AML, sanctions and fraud frameworks
  • Financial crime risk assessments aligned to products, customers and delivery channels
  • Regulatory remediation, Skilled Person reviews and supervisory engagement
  • Operational embedding of controls, governance and MI
  • Ongoing advisory, resourcing and managed financial crime support
How We Have Helped Our Clients
CASE STUDY: Providing Independent Assurance Over an Affordability Framework
Overview

Thistle Initiatives supported a UK FCA‑regulated consumer credit lender by providing independent assurance over the design and effectiveness of its affordability framework, with a focus on Consumer Duty outcomes and access to affordable credit.

 

Our Role

We carried out an independent review of the firm’s affordability framework to assess alignment with FCA expectations and industry best practice, and to provide assurance that controls were operating effectively in practice.

 

Key Deliverables

  • Reviewed affordability policies, underwriting processes and customer journeys against CONC and Consumer Duty requirements

  • Assessed how affordability assessments operated across different loan values and customer risk profiles

  • Benchmarked the framework against comparable approaches across the consumer credit market

  • Strengthened outcome‑focused management information to support oversight, challenge and evidencing


Impact

The firm was able to demonstrate that its affordability framework was robust, proportionate and delivering good customer outcomes in line with FCA expectations. Enhancements strengthened ongoing assurance, improved evidencing and increased confidence in the framework’s ability to meet evolving regulatory expectations.

 

Your Expert Team

Harry Cotton - 1200 rounded

Harry Cotton   linkedin-lead 1 mail
Partner and Head of M&A

Harry supports growth across all areas at Thistle Initiatives, with a particular focus on guiding clients and advisors through M&A in the Wealth space.

Prior to this, Harry served as a British Army Officer and later transitioned into Private Banking and Wealth Management, where he worked as a growth focused proposition lead and client advisor across a range of businesses. He also holds the Investment Advice Diploma and is an Associate member of the Chartered Institute for Securities and Investments.

Jessica Cath 1920 wide rounded corners (1)

Jessica Cath   linkedin-lead 1 mail
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.

Sam Coe website rounded

Sam Coe   linkedin-lead 1 mail
Partner, Change and Transformation

Sam has 14 years’ experience leading large scale change and transformation programmes in the Financial Services industry, working with several Tier 1 institutions across Banking, Insurance and Wealth and Asset Management. Sam started his career at KPMG before moving to Capco in 2017, where he was part of the Banking and Payments Leadership Team.

He has led numerous Regulatory Change programmes including remedial responses to s166, Consumer Duty and Operational Resilience. As well as this he also has vast experience delivering pre- and post- deal transformation programmes related to M&A activity such as new target operating model design and implementation and post-merger integration.

Matt Williamson
Matthew Williamson
Partner, Credit & Mortgages

Matt is a Credit & Mortgages Partner at Thistle Initiatives. He specialises in providing expert guidance to firms entering the financial services market, with a particular focus on credit and mortgage products.

Matt’s extensive knowledge and hands-on experience enable him to support clients through the complex regulatory landscape, from initial market entry to the successful launch of new products, ensuring compliance and strategic alignment at every stage.

Katie Fox
Katie Fox
Managing Director, Regulatory Compliance

Katie is a senior transformation specialist with deep expertise in regulatory interpretation and end to end implementation across the financial services sector.

With over 15 years’ experience delivering complex, multi-year programmes, she has led major regulatory change initiatives, guiding firms through the full lifecycle from rule interpretation and impact assessment to operating model redesign, systems change, governance uplift and BAU embedding.

Peter Lewis
Peter Lewis
Partner, Change and Transformation

Peter is a Partner in the Change and Transformation team, where he helps organisations deliver complex change with confidence. He brings more than 20 years’ experience across banking and broader financial services, advising boards and executives on operating model design, regulatory change and large scale transformation.

Alongside his consulting work, Peter is an experienced coach known for his practical approach, clear thinking and focus on building sustainable, people-centred outcomes.