Fraud Prevention Services

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.

Client

UK-based Institutional Investment group required assessment of Failure to Prevent Fraud risks.

How we helped

Thistle conducted a targeted risk assessment of the Firm’s fraud risks. The assessment included a review of relevant documentation, a workshop with key stakeholders, and an evaluation of inherent risk and control effectiveness.

The risk assessment consisted of the following principles:

 • Review of existing fraud processes and reporting lines
 • Assessment of fraud risks based on the Firm’s business model
 • Consideration of the principles outlined in the failure to prevent fraud offence guidance

Thistle produced a comprehensive Failure to Prevent Fraud risk assessment document that set out the relevant risk categories, associated controls and risk scoring outcomes.

In addition, Thistle provided a supporting report summarising the inherent fraud risks and control effectiveness, followed by a debriefing session with key stakeholders. 

Outcome

The final risk assessment and report provided the Firm with clear and actionable insights into its preparedness for the Failure to Prevent Fraud offence. The Thistle team quickly developed a strong understanding of the client’s systems and controls, asking insightful questions to identify potential fraud risks and evaluate the effectiveness of existing measures.

Thistle held a management response session to discuss the findings of the assessment and provided the Firm with a remediation plan outlining gaps and areas for improvement.

Client

UK-based Merchant Acquirer required independent audit of fraud systems and controls.

How we helped

Thistle conducted a comprehensive review of the Firm’s policies and procedures to assess their alignment with the FCA’s Payment Services Technical Standards. This was followed by a series of focused workshops with key members of the fraud and IT teams, covering areas such as systems architecture, IT security, team structure, risk management practices, real-time fraud monitoring and fraud rate calculations.

An in-depth review of the Firm’s fraud monitoring systems was then carried out to evaluate the effectiveness of alerts and responses. Random samples of fraud transaction alerts were tested to verify compliance with the technical standards. This step was an important part of determining whether the Firm’s controls were sufficiently robust to mitigate fraud risks effectively.

Thistle delivered a detailed and clearly structured report, providing a concise evaluation of the Firm’s compliance status and setting out how each technical standard was met, supported by evidence and practical insights. 

Outcome

The final report provided the Firm with clear and actionable insights into its fraud controls. The Thistle team quickly developed a strong understanding of the client’s systems and controls, asking thoughtful and probing questions to identify strengths and areas for improvement.

Thistle held a management response session to discuss the audit findings and provided the Firm with a solid basis to apply for the TRA exemption.