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Senior BSA Investigator
1 month ago
Under the direction of the Manager, BSA Investigations, the Senior BSA Investigator - Analyst ensures that Yaamava' Resort and Casino at San Manuel is compliant with the Bank Secrecy Act (BSA), the USA Patriot Act and the requirements of the Office of Foreign Asset Control (OFAC) as it pertains to casinos by investigating suspicious activities reported from the casino gaming floor and activity derived from data alert reports. The Senior BSA Investigator - Analyst performs in-depth research and analysis of facts and related information in the highly technical enhanced due diligence reports. Using the research/analysis conducted, the Senior BSA Investigator - Analyst independently prepares detailed analytical reports for casino compliance senior leadership, that includes recommended courses of action based on their analysis and exercise of sound judgment. In certain instances, the Senior BSA Investigator - Analyst is responsible for preparing Suspicious Activity Reports (SARs) for filing with the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN). This position also serves as a mentor for other BSA Investigators providing guidance and reviewing work for quality, accuracy, and completeness.
Essential Duties & Responsibilities
1. Performs highly complex technical, analytical, and detail-oriented work, relating to gaming records and activities, as well as gaming patterns of patrons to ascertain whether activity meets regulatory and internal policy criteria for possible suspicious activity reporting. Exercises independent judgment based on prior experience, training and education. Gathers, researches, interprets, and analyzes information from multiple systems, including but not limited to: AML System Case Management System, Synkros for slot and table ratings, Patron Authenticator, NeWave for electronic MTL/MIL, File Bound, and Tri-Tech.
2. Performs research using proprietary commercial databases to assess records relating to criminal arrests, indictments, convictions, civil litigation, regulatory actions, bankruptcies, business ownership (profit/loss statements), property ownership, negative news information, and related information. Reviews BSA/AML transaction monitoring alerts to assess suspicious activity. Assesses this information in relation to a patron's gaming and transaction activity to evaluate any potential suspicious activity, money laundering risk posed by patron, and possible exclusion recommendation.
3. Performs research using open source (internet) and social media sites to obtain information relevant to a patron's level of gaming and transaction activity. Investigates reported Suspicious Activity Incidents (SAIs) received from the casino gaming floor to assess whether the activity involves potential money laundering, terrorist financing or other related illicit activity.
4. Investigations will primarily consist of complex matters requiring the application of sound judgment and advance investigative skills. This will include, among others, complex investigations involving source of funds and source of currency investigations. These investigations will require, at minimum, enhanced due diligence procedures and the exercise of sound judgment in recommendations to senior leadership.
5. Escalates investigations involving highly sensitive matters per internal policies and procedures.
6. Prepares detailed investigative reports for casino compliance senior management which provide a recommendation as to whether a patron's gaming or transactional activity is suspicious and thereby 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) or rationale for recommended courses of action.
7. Under the direction of management, prepares SARs, including the review of the narrative, which requires the ability to articulate the facts for the benefit of law enforcement, and ultimately the filing the U.S. Department of the Treasury, specifically FinCEN.
8. Assists in the development of standard investigative procedures and protocols. These procedures and protocols will also include methodologies and typologies relating to money laundering schemes and related financial fraud schemes. Reviews and analyzes new and pending laws and regulations and develop or revise appropriate policies, procedures contracts and agreements.
9. Provides advice and guidance to other BSA investigators on investigative matters as well as reviews quality of work for accuracy, and completeness.
10. Performs other duties as assigned to support the efficient operation of the department.
Education/Experience/Qualifications
- Bachelor's degree in Forensic Accounting, Business Administration, Criminal Justice, and/or related field is required.
- Three (3) years of Anti-money laundering or other related investigative experience is required.
- Five (5) years of Anti-money laundering experience is preferred.
- Equivalent combination of education and progressive, relevant, and direct experience may be considered in lieu of minimum educational/experience requirements indicated above.
- Previous casino experience is a plus.
- Must have strong working knowledge of the BSA/AML and suspicious activity regulatory requirements.
- Must possess thorough working knowledge of the Anti-Money Laundering policies and procedures for Title 31 transaction reporting departments (i.e., Cage Operations and Table Games) is preferred.
- Must be able to analyze accounts/transactions/activity to identify anomalies and suspicious activity.
- Must possess intermediate proficiency in Microsoft Office Suite (Word, Excel, and Outlook), commercial database systems, and internet research skills.
- Must possess excellent report writing skills and verbal communication skills.
- Must have the ability to work independently with minimal supervision.
- Must maintain the highest degree of confidentiality with respect to critical matters involving Casino's AML Program.
- At the discretion of the San Manuel Tribal Gaming Commission, you may be required to obtain and maintain a gaming license.
- A qualified candidate/employee must have a valid driver's license with an acceptable driving record as determined by the company's insurance carrier.
- Professional certification as a Certified Anti-Money Laundering Specialist through the Association of Certified Anti-Money Laundering Specialists (ACAMS) is preferred.
Yaamava' Resort and Casino at San Manuel will make reasonable accommodations in compliance with applicable law.
As one of the largest private employers in the Inland Empire, San Manuel deeply cares about the future, growth and well-being of its employees. Join our team today