AML/CFT Services
“]
Under 31 CFR Chapter X, each financial institution is required to implement a written AML/CFT program that is risk-based and reasonably designed to prevent the business from being used for money laundering, terrorist financing, or other illicit finance activities. The AML/CFT program must be designed to ensure compliance with the applicable provisions of the Bank Secrecy Act and its implementing regulations. Among other things, the BSA’s implementing regulations require the designation of an AML/CFT compliance person, training of personnel, independent testing (or “audit”) of the AML/CFT program, and conducting ongoing customer due diligence. To ensure that the program is risk-based and reasonably designed, a money laundering and terrorist financing (ML/TF) risk assessment must be conducted and documented. SIRS’ comprehensive AML/CFT compliance services address each of these requirements.
As shown on our pricing page, SIRS uses a transparent, flat-rate pricing model. Comprehensive AML/CFT services are priced within a fixed range for each business category (investment adviser, mortgage broker or lender, securities broker/dealer, precious metals & jewelry dealer). After reviewing the business size and other factors, SIRS will provide a service agreement in which a flat-rate price is given. Read more…
ML/TF Risk Assessment
Under the AML Act of 2020, a financial institution is required to implement a risk assessment process. The risk assessment process must serve to “identify, evaluate, and document the financial institution’s risks, including consideration of… the money laundering and terrorist financing (ML/TF) risks of the financial institution, based on a periodic evaluation of its business activities, including products, services, channels, customers, intermediaries, and geographic locations….”
After conducting a review of the client’s business activities, SIRS will prepare a written assessment of the ML/TF risks to which the client is exposed. The assessment will draw upon applicable guidance given by FinCEN, FATF, the US Treasury Department and other reliable sources. The completed risk assessment will serve as the basis for the client’s AML/CFT compliance program.
AML/CFT Compliance Program
Based on the client’s business activities and relevant BSA criteria, SIRS will prepare a customized AML/CFT program (or “written program”). To demonstrate relevance and accuracy, the written program will reference and include links to the industry-specific regulations found in the various sections of 31 CFR Chapter X.
The AML/CFT program will be risk-based and reasonably designed. Including an index and easy-to-understand text, the written program will serve as a useful resource to the client. With clear and concise policies and procedures, and avoiding excessive and unnecessary verbiage, SIRS’ AML/CFT programs are often shorter than the written programs prepared by service providers who use excessive (and often irrelevant) verbiage. Depending on the industry, SIRS’ AML/CFT program will typically be from 15-20 pages in length.
AML/CFT Training
Training is one of the main pillars of a financial institution’s AML/CFT program. As a best practice, an institution should ensure that its personnel complete an AML/CFT training course each year.
SIRS offers online AML/CFT training courses for RIAs, RMLOs, and precious metals & jewelry dealers. Each of these sector-specific courses is tailored to the risks and regulatory requirements applicable to the business sector. Each course takes 12-14 minutes to complete and is priced at just $12. After successfully completing the course and quiz, a completion certificate is awarded.
Independent Test (or “Audit”)
SIRS’ Independent AML/CFT testing service consists of a comprehensive review of the client’s AML/CFT program. The test takes a two-pronged approached which includes 1) a review of the client’s written AML/CFT policies and procedures to ensure that they address relevant (industry specific) BSA criteria, and 2) a review of AML/CFT records maintained by the client which demonstrate the performance of procedures specified in the written program. After completing a test, a written report will be provided. The written report will include SIRS’ findings and, if gaps are found, recommendations for improving the program. Throughout the testing process, SIRS will function as a partner to the client. As gaps in the client’s AML/CFT program are identified, where possible, SIRS will collaborate with the client to resolve or mitigate the problem before the test is completed. In this way, the final test report can present the client in a more favorable light.