Pricing & Enrollment

AML Programs & Independent Testing

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

SIRS’ services for RMLOs include:

  • Written Policies and Procedures. SIRS’ 11-page AML compliance program contains the policies and procedures needed to address AML regulations governing RMLOs.
  • Mortgage Fraud and Money Laundering Review (MFMLR) form. SIRS’ MFMLR form can be easily integrated into your loan origination process. Use of the MFMLR will provide documentation of your firm’s compliance with its obligation to monitor applications in order to detect suspicious activities.
  • Independent AML Test. As required by the BSA (31 C.F.R. § 1029.210(b)(4)), SIRS will conduct an independent test (review) of your policies, procedures, and documented practices. After conducting the test, we will provide you with a report of our findings. With each finding, we will provide a recommendation for addressing the identified deficiency.

Registered Investment Adviser (RIA): $5,500+

SIRS’ services for RIAs include:

  • Written Policies, Procedures, and Internal Controls (AML/CFT Program). This risk-based program addresses BSA regulatory requirements governing the RIA’s investment advisory activities.
  • Risk Assessment. To ensure that the RIA’s 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 dealings. A report of the assessment 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 the test is completed, you will receive a detailed test report.
  • AML/CFT Training. Access to an online training module covering the major points of AML/CFT
    regulatory requirements for RIAs will also be provided    .

Securities Broker/Dealer: $4,500+

Since 2007, SIRS has been a respected provider of B/D compliance services. 

SIRS’ services for broker/dealers include:

  • Independent AML Test. As required by FINRA Rule 3310(c), SIRS will conduct an independent test of your AML compliance program. After the test is completed, you will receive a detailed test report that includes SIRS’ findings and recommendations. With each finding, we will provide a recommendation concerning for addressing the identified deficiency.

Note regarding FINRA’s AML Template for Small Firms:
While some updates are needed, FINRA’s AML Small Firm Template provides an excellent set of AML policies and procedures for broker/dealers. SIRS recommends that a B/D adapt FINRA’s template to fit its business model.

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

SIRS’ services for precious metals and jewelry dealers include:

  • Written Policies and Procedures. SIRS’ AML compliance program contains the policies and procedures needed to addresses BSA/AML regulations governing precious metals and jewelry dealings. Among other things, this document includes a risk assessment and a list of records that must be created and maintained by dealers.
  • Independent AML Test. As required by 31 C.F.R. § 1027.210(b)(4), SIRS will conduct an independent test (review) of your AML compliance program. After the test is completed, you will receive a detailed report that includes SIRS’ findings and recommendations. With each finding, we will provide a recommendation for addressing the identified deficiency.

Enrollment

To request a service agreement, contact SIRS via telephone (866.568.7151) or email (info@sirsco.com).