Pricing & Enrollment

AML Programs & Independent Testing

Residential Mortgage Lender & Originator (RMLO): $500-$1,000+ (broker), $1,000-$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.

Payment Processors, Payment Facilitators, and ISOs: $3,500+

While their services are not covered by BSA regulatory requirements, merchant payment processors and payment facilitators present money laundering risks to their sponsor banks. SIRS’ services will provide the documentation needed for a payment processor, PayFac, or ISO to demonstrate to a sponsor bank that a risk-based AML program has been implemented.

SIRS’ AML compliance services for ISOs, PayFacs, and payment processors include:

  • Written Policies, Procedures, and Internal Controls (AML Compliance Program). This risk-based program presents the regulatory background and framework for addressing the money laundering and terrorist financing risks encountered by merchant payment processors and ISOs.
  • Independent Review. SIRS will conduct a review of your policies, procedures and internal controls to ensure that they address applicable BSA/AML regulatory requirements. After conducting the review, you will be given a report of SIRS’ findings and recommendations.
  • AML Training. You will receive access to an online AML training course for each of your employees. After completing the training course, each person will receive a certificate of training.

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).