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 approval 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 annual review of your policies, procedures and business practices to ensure that they are in compliance with AML requirements. After conducting the test, we will provide you with a 2-5 page report of our findings. With each finding, we will provide our expert recommendation concerning the best way to correct the 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 all applicable AML regulatory requirements. After conducting the review, you will be given an 8-10 page 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: $3,000 – $6,500
Since 2007, SIRS has been a respected provider of B/D compliance services. SIRS is listed in the FINRA Compliance Vendor Directory.
SIRS’ services for broker/dealers include:
- Independent AML Test. As required by FINRA Rule 3310(c), SIRS will conduct an independent review 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 our expert recommendation concerning the best way to address the 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 AML regulations governing precious metals and jewelry dealers. Among other things, this document includes a comprehensive AML compliance program, the risk assessment required by BSA § 1027, a list of records that must be created and maintained by dealers, and an annual report form that will allow for easy documentation of many required activities.
- 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 test report that includes SIRS’ findings and recommendations. With each finding, we will provide our expert recommendation concerning the best way to address the deficiency.
To request a formal quotation, contact SIRS via telephone (866.568.7151) or email (email@example.com). We will respond by sending you the quotation and additional information about our services.