SIRS’ AML/CFT compliance services address the specialized needs of non-bank financial institutions, including SEC-registered investment advisers (RIAs) and exempt reporting advisers (ERAs), residential mortgage lenders and originators/brokers (RMLOs), securities broker/dealers (B/Ds), and precious metals and jewelry dealers. Understanding the need for efficiency and cost-effectiveness, SIRS uses a transparent, flat-rate pricing model. As shown below, SIRS prices its comprehensive AML/CFT services within a fixed range for each business category.
SIRS’ RIA AML/CFT training course covers BSA regulatory requirements for investment advisers and exempt reporting advisers.
SIRS will assess the money laundering and terrorist financing risks that the RIA may encounter in its business dealings. Upon completing the assessment, SIRS will deliver a written risk assessment report to the RIA.
SIRS will independently test the RIA’s AML/CFT Program by reviewing 1) the firm’s written policies and procedures, and 2) records that demonstrate compliance with AML/CFT obligations. After completing the test, SIRS will provide a detailed report outlining its findings and recommendations.
The AML/CFT program includes internal policies, procedures, and controls designed to ensure adherence to AML/CFT regulations governing investment advisory activities. To develop the program, SIRS will first analyze the client’s business dealings and exposure to money laundering and terrorist financing risks. This approach ensures that the AML/CFT program is both relevant and appropriately risk-based.
The AML/CFT compliance program comprises a comprehensive set of internal policies, procedures, and controls designed to ensure compliance with AML/CFT regulations applicable to the residential mortgage industry. As a foundational component of this program, SIRS will conduct and document an AML/CFT risk assessment. This assessment will be incorporated into the written AML/CFT compliance program to enhance risk management and regulatory adherence.
The Financial Crimes Enforcement Network (FinCEN) has identified mortgage fraud as a primary risk for mortgage brokers and lenders. To mitigate this risk, the Mortgage Fraud and Money Laundering Review (MFMLR) form may be integrated into the loan origination or underwriting process. This form serves as a streamlined tool for brokers and lenders to systematically document their monitoring efforts and identify potential indicators of mortgage fraud.
In accordance with BSA requirements (31 C.F.R. § 1029.210(b)(4)), SIRS will conduct a test/audit of the AML/CFT program of the broker or lender. The test will include a comprehensive review of written policies and procedures. It will also include a targeted evaluation of relevant documentation maintained by the broker or lender. Upon completion, SIRS will deliver a detailed test report outlining any identified gaps and providing actionable recommendations to address deficiencies.
SIRS’ RMLO AML/CFT training course covers the major points of AML/CFT regulatory requirements for mortgage brokers and lenders.
The AML/CFT compliance program consists of internal policies, procedures, and controls designed to address AML/CFT regulations governing precious metals and jewelry dealings. As a foundational part of the program, SIRS will conduct an AML/CFT risk assessment and will include the assessment in the compliance program.
As required by 31 C.F.R. § 1027.210(b)(4), SIRS will conduct an independent test/audit of the client’s AML/CFT program. The test will include a review of the client’s written policies and procedures, and a review of documentation maintained by the client. After conducting the test, SIRS will provide a detailed report. With each gap (if any) identified in the report, SIRS will provide a recommendation for addressing the deficiency.
SIRS’ AML/CFT training course for precious metals and jewelry dealers covers relevant BSA regulations governing precious metals and jewelry dealings.
As required by FINRA Rule 3310, SIRS will conduct an independent test of the B/D’s AML/CFT program. The test will include a review of the B/D’s written policies and procedures and of documentation maintained by the B/D. After conducting the test, SIRS will provide a detailed report of its findings and recommendations. For each identified gap, SIRS will provide a recommendation for addressing the deficiency.
