Industries

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

SIRS’ AML/CFT compliances 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 & jewelry dealers. Understanding the need for efficiency and cost-effectiveness, SIRS uses a transparent, flat-rate pricing model. As shown below, SIRS provides comprehensive AML/CFT services and prices these services within a fixed range for each business category.

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

SIRS’ AML/CFT services for RIAs and ERAs include:

  • Internal Policies, Procedures, and Controls (AML/CFT Program). This risk-based program addresses 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. A written risk assessment report will be provided. 
  • Independent Test of AML/CFT Program. As required by the BSA, 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 test report.
  • AML/CFT Training. Access to an online training course covering the major points of AML/CFT regulatory requirements for RIAs will be provided.

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

SIRS’ services for RMLOs include:

  • Written Policies and Procedures. 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. An AML/CFT risk assessment will be included in the 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. Use of this form allows a broker or lender 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 conducting the test, SIRS will provide a detailed report of findings and recommendations. With each gap (if any) identified in the test report, SIRS will provide a recommendation for addressing the deficiency.
  • AML/CFT Training. Access to an online training course covering the major points of AML/CFT regulatory requirements for RMLO’s will be provided.

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

SIRS’ services for precious metals and jewelry dealers include:

  • 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, a report will be provided. With each gap (if any) identified in the test report, SIRS will provide a recommendation for addressing the deficiency.
  • AML/CFT Training. Access to an online training course covering the major points of AML/CFT regulatory requirements for precious metals and jewelry dealings will be provided.

Securities Broker/Dealer: $4,500+

As required by FINRA Rule 3310(c), SIRS will conduct an independent test of the B/D’s AML/CFT compliance program. After completing the test, SIRS will provide a detailed report. The test report will include SIRS’ findings and recommendations. With each identified gap, SIRS will provide a recommendation for addressing the deficiency.