Financial Crime Compliance - Thistle Initiatives

With strong focus and scrutiny from the UK regulators, getting financial crime compliance wrong, can have serious economic and reputational consequences

We don't recite regulations. We have the tools to help you interpret the rules and implement controls, with a custom fit for your products and services. Your compliance framework will be verified by experts, meaning your firm will be in the best position to avoid any big surprises from the FCA.

Support through complexity

We support firms to navigate the complexities of financial crime regulations, including
providing firms with practical, scalable and industry best practice advice based on our extensive knowledge and experience.

Protect your business

There is no one size fits all solution to the challenge of financial crime compliance, but our specialist financial crime team is here to help you protect your business, your customers, and your good standing with the regulators.

Guard against risk

We can help you guard your business against all aspects of financial crime risk, including Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF), Anti-Bribery and Corruption (ABC), Anti-Facilitation of Tax Evasion (AFTE), sanctions evasion and
fraud.

We offer these services, amongst many others, to keep your financial crime compliance under control

Applications

FCA / HMRC Application or Registrations

Supporting you through the end-to-end application process, from drafting documentation to advising on communication with the regulator. Thistle has supported a range of firms including EMIs / APIs and crypto, through to high-value dealers.

Interview Preparation

Thistle can provide key individuals with support and preparation for interviews with regulators, to make sure you have the knowledge and expertise to successfully meet the fit and proper
requirements.

Business-wide Risk Assessments

Preparing or enhancing your business-wide risk assessment for financial crime by identifying risks in meeting your AML responsibilities and controls in place to mitigate them.

Policies and Procedures

Thistle can draft, review and revise internal policies and procedures that are bespoke to your firm, to ensure AML compliance at the application stage or as your firm grows and changes.

Implementation

AFC Controls

Designing and implementing any AFC control, inclusive of procedure documents and tools as required. Example controls include onboarding and ongoing monitoring, transaction monitoring, anti-fraud, and screening.

Vendor Implementation

Thistle can support with all elements of AFC vendor implementation. Thistle can design and run a request for proposal (RFP) process for new vendor solutions, and support testing to
ensure a smooth transition to BAU.

Business risk assessment

Identifying risks in meeting your AML responsibilities and putting steps in place to mitigate them.

Policies and procedures

A review and revision, where needed, of internal policies and processes to ensure AML compliance.

Customer journey

Looking at each touchpoint to ensure both the business and customer are protected.

Advice

Regulatory Enforcement

Thistle can provide expert advice and practical support to firms preparing for or under-skilled person reviews (Section 165 and Section 166). We utilise our team’s previous experience of either undertaking reviews or having gone through reviews ourselves to support you through the journey.

Ad hoc or Retained Advice

Thistle can provide financial crime advisory services on an ad-hoc or retained basis to ensure you always have the right expert to speak to.

Training

Training is a requirement of an effective AML programme. Thistle provides both standard and bespoke anti-financial crime training and workshops to staff, from analysts through to senior managers and board members.

Transformation

AFC Remediation

Providing rapid, practical support to remediate any control failures. Thistle can build and manage your remediation plan, as well as supporting communication and reporting to the regulator.

Enhancing AFC Controls

Providing expert advisory solutions to refine, rebuild and enhance existing controls. Examples include refining transaction monitoring rules or adjusting sanctions screening configurations.

Assurance

AML Audits

Independent AML audits to assess a firm’s control framework, demonstrate how firms mitigate financial crime risk, and identify where improvements are needed. Audits include a full review of documentation, interviews, file reviews and testing.

Health Check

Health check to identify weak spots in AFC controls, and make practical recommendations for remediation. Health checks are designed to provide comfort through a review of
documentation, without the audit testing.

Targeted Assurance

Conduct targeted assurance of a specific control area (such as screening or transaction
monitoring), identifying any weaknesses and providing practical recommendations.

M&A Due Diligence

Reviewing financial crime controls as part of M&A due diligence. Ensuring all M&A activity complies with corruption, fraud and AML compliance regulations.

Outsourcing

Backlogs or Look-back Exercises

Thistle provides expert resources to support with backlogs or look-back exercises. This could include providing analysts to conduct transaction monitoring backlogs or KYC back-book reviews.

Secondments

Thistle provides resources on secondment to perform BAU tasks during periods of increased
workload or to address expertise gaps. This can include secondments into either the first or second line of defence teams.

Fraud services

Prevent

Fraud Risk Assessment
Fraud Strategy & Policy Review
Fraud Controls Assessment (APP Specific)
Corporate Failure to Prevent Fraud Preparation
Fraud Training
Fraud Awareness Campaigns

Detect

Fraud Audit
Fraud Health Check
Transaction Monitoring
Speak Up Review

Remediate

Fraud Rapid Response Remediation
Fraud Reporting Review
Fraud Resource Support
Fraud Investigations

Our company needed a quick turnaround for an AML audit so we approached Thistle Initiatives who was happy to help. The team at Thistle were very professional; commencing and completing the audit within a tight schedule. The process was undertaken in a very efficient way and Thistle delivered a report of high standard, including an in-depth analysis of our AML infrastructure. Overall, we have received great service from Thistle and will recommend their services

OpenPayd

What our clients have to say

“As Head of Compliance / MLRO, I found that from drafting the review scope from our initial RFQ and throughout the process, Thistle was very professional, and managed the review timetable so that that the review was completed on time and without delay.

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.”

Equiti

“Thistle has supported us with our ongoing compliance requirements ever since they assisted us to become an authorised EMI. The team are highly knowledgeable in both the EMI and AML regulatory space. They are thorough and constructive with any feedback or advice and are able to assist with complex compliance matters in a digestible way, with a commercial mindset."

VertoFx

“We have used Thistle’s compliance services since 2016 and will continue to do so to help reach our business objectives. Thistle worked with us on our FCA Crypto Application with very short notice and delivered an application ready to submit to the FCA at a very high standard. I can only attribute this excellent turnaround to Thistle’s relentless work ethic and their deep understanding of the regulatory landscape.”

Bitstocks

“KoinKoin owes her registration with the FCA to the team over at Thistle Initiatives who were able to bring the best and brightest in regulatory risk and assist us with building our regulatory profile. We would work with Thistle again in the future and we will be seeking their counsel for the MLR registration in 2021.”

KoinKoin

“Thistle understood our brief for streamlining the onboarding process accurately, taking care and diligence to understand the pain points and potential areas of improvement. Jess and the team delivered clear and insightful feedback, which I’m sure will vastly improve and accelerate the current onboarding process.”

OpenPayd

“Thistle clearly understood what we needed and provided a clear and transparent scope of work and quote. The project was well resourced, and the deliverables were of a high standard. We wouldn’t hesitate to use Thistle again.”

Thincats Limited

“The whole audit process was very professional from start to finish. The process and methodology were clearly explained from the start. The team were very professional, good listeners and always contextualise their recommendations and action rationale.”

Premier Payment Solutions Ltd

“Working with Thistle on our recent AML audit was an absolute pleasure. Their team demonstrated exceptional professionalism, expertise, and efficiency throughout the entire process. Not only did they complete the audit promptly, but their warm approach during sessions was appreciated, and results were delivered results to an incredibly high standard. We are now more capable of navigating the complexities of compliance thanks to their in-depth knowledge of AML regulations and customised approach to the cryptoasset sector. We highly recommend Thistle to any business looking for the best compliance services available.” Archax Ltd

Archax Ltd

Financial Crime

Solutions tailored to you

Support through complexity

Protect your business

Guard against risk

Financial Crime service areas

We offer these services, amongst many others, to keep your financial crime compliance under control

Applications

FCA / HMRC Application or Registrations

Interview Preparation

Business-wide Risk Assessments

Policies and Procedures

Implementation

AFC Controls

Vendor Implementation

Business risk assessment

Policies and procedures

Customer journey

Advice

Regulatory Enforcement

Ad hoc or Retained Advice

Training

Transformation

AFC Remediation

Enhancing AFC Controls

Assurance

AML Audits

Health Check

Targeted Assurance

M&A Due Diligence

Outsourcing

Backlogs or Look-back Exercises

Secondments

Fraud services

Prevent

Detect

Remediate

We can support you in these areas of legislation and guidance

Anti-Money Laundering

Anti-Bribery, Corruption, and Facilitation of Tax Evasion

Counter-Terrorist Financing

Fraud

Who we support

What our clients have to say

Your point of contact