With strong focus and scrutiny from the UK regulators, getting financial crime compliance wrong, can have serious economic and reputational consequences
Solutions tailored to you
We apply our detailed knowledge of regulation, industry best practice, and financial crime risk to create practical tailored solutions for your firm.
We offer effective assistance ranging from outsourced operational due diligence, framework audits, desktop and face-to-face training and assistance in interpreting and implementing the regulations and legislation.
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
Financial Crime service areas
We support firms in all elements of the Anti-Financial Crime (AFC) framework throughout their journey from initial application, through implementation, to assurance and outsourcing.
We offer these services, amongst many others, to keep your financial crime compliance under control
FCA / HMRC Application or Registrations
Business-wide Risk Assessments
Policies and Procedures
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.
Looking at each touchpoint to ensure both the business and customer are protected.
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.
Enhancing AFC Controls
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 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.
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
Backlogs or Look-back Exercises
workload or to address expertise gaps. This can include secondments into either the first or second line of defence teams.
We can support you in these areas of legislation and guidance
A firm should demonstrate its commitment to opposing the risk of money laundering by implementing a robust oversight and framework structure considering the following guidance:● The Money Laundering Regulations
● Proceeds of Crime Act
● Joint Money Laundering Steering Group Guidance
● Wolfsberg Guidance
● Industry-specific HMRC guidance
Anti-Bribery, Corruption, and Facilitation of Tax Evasion
It is illegal to offer, promise, give, request, agree to, receive or accept bribes - an anti-bribery policy can help protect your business. As a minimum, a firm must consider the following when implementing robust controls:● Bribery Act 2010
● Ministry of Justice Guidance
● Criminal Finances Act
● HMRC Guidance Notes
The UK has a robust legislative framework which criminalises the financing of terrorism in all its forms and engaging with sanctioned
entities, and includes and includes:
● Terrorism Acts
● Sanctions Acts
Fraud is when trickery is used to gain a dishonest advantage, which is often financial, over another person. The following legislation and industry bodies are in place to help stop fraud:
● Fraud Act
● FCA's Handbook Guidance
● Action Fraud Guidance
Who we support
We support businesses from a range of industries to unravel their financial crime compliance responsibilities
- Betting shops
- Wealth Management
- High net worth
- Estate agents
- Money service business
And many more...
What our clients have to say
Your point of contact
Jessica is a financial crime leader, working with a range of firms to build, scale, and assure all elements of the financial crime framework. Jess works with firms throughout their application process, as well as drafting documentation and implementing tools, to enhancing and transforming controls when things change. Jess also has extensive experience with audits and skilled person reviews in the UK and abroad.