AML Independent Testing
Fixed-fee BSA/AML reviews for RIAs, broker-dealers, fintechs, MSBs, and private funds. Scoped, productized, audit-ready.
Three Fixed-Fee Tiers
Final pricing depends on the scoping questionnaire below. Bundle with a RegReview subscription for 10–15% off.
AML Review – Essentials
Independent BSA/AML testing for smaller RIAs with low-risk client bases.
- Policy & procedures review
- CIP / KYC sampling
- OFAC / sanctions screening test
- Risk assessment refresh
- Written independent test report
Best for: RIA, ≤$500M AUM, no custody, primarily US individual clients
AML Review – Standard
Full FinCEN / FINRA 3310 independent testing for BDs and RIAs serving funds.
- Everything in Essentials
- Transaction monitoring sample testing
- SAR / CTR filing review
- Training program assessment
- AML officer interview & control walkthroughs
- Findings memo + remediation plan
Best for: Broker-Dealers, RIAs to private funds, mid-size firms
AML Review – Complex
Risk-based independent testing for fintech, MSBs, and multi-entity programs.
- Everything in Standard
- Multi-entity / multi-jurisdiction scope
- Enhanced transaction monitoring testing
- Third-party / BaaS partner program review
- State MTL & FinCEN MSB compliance check
- Executive readout + board-ready report
Best for: Fintech, BaaS, money transmitters, neobanks, crypto-adjacent, MSBs
Why AML Testing Matters in 2026
FinCEN Final Rule (Effective Jan 1, 2026)
SEC-registered RIAs and ERAs are now subject to BSA/AML program requirements, including independent testing.
FINRA Rule 3310
Broker-dealers must complete independent AML testing annually (or every two years for limited-business firms).
State MTL & MSB Programs
Money transmitters, fintechs, and BaaS partners face multi-state and FinCEN MSB testing expectations.
Penalties Are Climbing
2024–2025 AML enforcement actions averaged $5M+ per firm; even small RIAs see $25K–$250K deficiency settlements.
AML Review Scoping Form
Answer a few questions and we'll send a fixed-fee proposal within 1 business day.