This position is responsible for Title 31 Compliance program day-to-day activity including CTR and SAR documentation, investigation, review, reporting, and filing; assist in training of all company personnel and assisting the Compliance Officer in preparing materials, as needed to fulfill their role.
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Primary Duties and Responsibilities:
- Responsible for assisting in implementation and enforcement of the Title 31 Compliance program.
- Assists Compliance Officer with developing and recommending policies and standard operating procedures as it relates to the Bank Secrecy Act requirements
- Provides guidance to gaming operations and other departments.
- Collect manual and system sourced documentation as it relates to Title 31.
- Review daily reports of cash transactions, suspicious activity and supporting documentation for completeness and accuracy. Issue Title 31 Exception Notices for instances of non-compliance and ensure corrective actions are performed to facilitate compliance.
- Entry of all patron information, W-2G, W-9, 1099.
- Entry of MTL’s into the in-house AML database.
- Maintenance of in-house AML database.
- Analyze and aggregate daily, weekly, monthly, and quarterly reports to determine filing requirements.
- Investigate transactions for missing or additional information needed.
- Perform complex technical, analytical, and detail-oriented work relating to gaming records, activities as well as gaming patterns of patrons to ascertain whether the activity meets regulatory and internal policy criteria for possible suspicious activity reporting
- Gathers, and analyzes information from multiple systems, including but not limited to; credit card advances, check cashing systems, Multiple Transaction Logs, and in-house database.
- Perform research using a commercial database to assess records relating to criminal arrests, indictments, convictions, civil litigation, regulatory actions, bankruptcies, business ownership, property ownership, negative news information, and related information. Employees will assess this information in relation to a patrons gaming and transaction activity to evaluate any potential suspicious activity and/or money laundering risk posed by patron.
- Performs research using open source (internet) and social media sites to obtain information relevant to a patron’s level of gaming and transaction activity. Investigate Suspicious Incident Reports (SIRs) received from the gaming floor to assess whether the activity involves potential money laundering, terrorist financing or other related illicit activity.
- Investigations will range in complexity. Some may require minimal due diligence pertaining to the specific activity while others may involve complex source of funds investigations involving enhanced due diligence procedures and exercise of sound judgment in recommendations to the Compliance Officer.
- Review CTRs timely and accurately for filing with FinCEN.
- Prepares detailed investigative reports to the Compliance Officer which provide a recommendation as to whether a patrons gaming or transactional activity is suspicious and requiring a SAR filing or if a No-SAR determination is more appropriate. The recommendation will be based on an assessment of internal gaming data sources, external commercial data sources, internet, and other sources. The recommendation will involve an analytical assessment of all available information and the exercise of judgment that includes a description of their reason(s) for recommended courses of action.
- Under the direction of the Compliance Officer, prepare SARs including narratives for filing.
- Assist with OFAC, KYC, CDD, and EDD reviews
- Collaborate with other gaming departments to obtain and maintain information to complete suspicious activity monitoring.
- Conduct data analysis and other investigation techniques for reportable activities.
- Prepare training materials for training classes. Assist in administering Title 31 training.
- Assist in preparation for annual independent review. Cooperate with independent review to provide requested information and follow up.
- Attend required company training and meetings.
- Must maintain the strictest confidence of any and all confidential information.
Qualifications:
- Knowledge of Bank Secrecy Act regulations and Title 31 compliance reporting and filing preferred but not required.
- Excellent written and verbal communication skills.
- Excellent organizational and multi-tasking skills.
- Proficient in Microsoft Access, Word, Excel, PowerPoint, and Outlook.
- Ability to comprehend regulatory and reporting standards and requirements.
- Must be able to work in a fast-paced environment with frequent interruptions.
- Must be willing to work in office Monday - Friday
- Travel may be required.
Benefits:
• Cafeteria plan offered after 60 days
• 401K enrollment after one year
bestbet is a drug free workplace.