Industries Serviced

AML/CFT Services for RIAs, B/Ds, RMLOs, and Precious Metals Dealers

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.

Registered Investment Adviser and Exempt Reporting Adviser (RIA and ERA): $5,500+

Investment Adviser AML services, RIA AML policy, RIA AML audit, RIA AML test, RIA AML risk assessment

Internal Policies, Procedures, and Controls (AML/CFT Program)

These risk-based policies and procedures address BSA regulatory requirements governing the client’s investment advisory activities.

Risk Assessment

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.

Independent Test of AML/CFT Program

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. 

AML/CFT Training

SIRS’ RIA AML/CFT training course covers the major points of BSA regulatory requirements governing investment advisers and exempt reporting advisers.

Residential Mortgage Lender & Originator (RMLO): Broker - $750-$1,500+; Lender - $1,500-$2,500+

AML/CFT Compliance Program and Risk Assessment

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.

Mortgage Fraud and Money Laundering Review (MFMLR) form

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.

Independent AML/CFT Test

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.

RMLO AML, mortgage AML policy, mortgage lender AML, mortgage aml risk assessment, mortgage broker aml test, mortgage aml audit

AML/CFT Training

SIRS’ RMLO AML/CFT training course covers the major points of AML/CFT regulatory requirements for RMLO’s.

Dealer in Precious Metals, Stones & Jewels: $750-$1,500+

Gold AML, jewelry AML, coin dealer AML

Written Policies and Procedures

The AML/CFT compliance program consists of internal policies, procedures, and controls designed to address AML/CFT regulations governing precious metals and jewelry dealings. An AML/CFT risk assessment will be included in the compliance program.

Independent AML/CFT Test

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.

AML/CFT Training

SIRS’ AML/CFT training course for precious metals and jewelry dealers covers relevant BSA regulations governing precious metals and jewelry dealings.

Securities Broker/Dealer: $4,500+

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.

broker/dealer aml, bd aml independent test, FINRA rule 3310