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.
These risk-based policies and procedures address BSA regulatory requirements governing the client’s investment advisory activities.
To ensure that the AML/CFT program is risk-based (as required by § 1032.210(a)(1)), SIRS will conduct an assessment of money laundering and terrorist financing risks to which the RIA may be exposed in its business activities. After completing the assessment, SIRS will provide a written risk assessment report.
SIRS will conduct an independent test of the RIA’s AML/CFT Program. The test will consist of 1) a review of the RIA’s written policies and procedures and 2) a review of records which evidence the RIA’s performance of obligations specified in the written program. After completing the test, SIRS will provide a detailed report of its finding and recommendations.
SIRS’ RIA AML/CFT training course covers the major points of BSA regulatory requirements governing investment advisers and exempt reporting advisers.
The AML/CFT compliance program consists of internal policies, procedures, and controls designed to address AML/CFT regulations governing residential mortgage lending and brokering activities. As the basis for the written program, SIRS will conduct and document an AML/CFT risk assessment. SIRS will include the risk assessment as part of the written AML/CFT compliance program.
FinCEN has identified mortgage fraud as the main risk to which mortgage brokers and lenders are exposed. To address this risk, the MFMLR form may be integrated into the loan origination or underwriting process. A broker or lender may use this form to easily document its monitoring of loan applications for signs of mortgage fraud.
As required by the BSA (31 C.F.R. § 1029.210(b)(4)), SIRS will conduct an independent test/audit of the RMLO’s AML/CFT program. The test will include a review of written policies and procedures, and a limited review of documentation maintained by the RMLO. After completing the test, SIRS will provide a detailed test report. With each gap (if any) identified in the test report, SIRS will provide a recommendation for addressing the deficiency.
SIRS’ RMLO AML/CFT training course covers the major points of AML/CFT regulatory requirements for RMLO’s.
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 written policies and procedures, and a limited review of documentation maintained by the client. After conducting the test, SIRS will provide a detailed test 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 policies and procedures. After completing the test, SIRS will provide a detailed test report. In the report SIRS will provide findings and recommendations. Foreach identified gap, SIRS will provide a recommendation for addressing the deficiency.