Under the direction of the Manager, BSA Investigations, the BSA Investigator - Analyst ensures that Yaamava’ Resort & Casino is compliant with the Bank Secrecy Act (BSA), the USA Patriot Act and the requirements of the Office of Foreign Assets Control (OFAC) as it pertains to casinos. The BSA Investigator - Analyst investigates reported suspicious activities from the casino gaming floor and activity derived from data alert reports. The BSA Investigator - Analyst performs in-depth research and analysis of facts and related information. Using the research/analysis conducted, the BSA Investigator - Analyst independently prepares detailed analytical reports for senior leadership that includes recommended courses of action based on their analysis and exercise sound judgment. In certain instances, the BSA Investigator - Analyst is responsible for preparing Suspicious Activity Reports (SARs) to file with the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN).
Essential Duties & Responsibilities
1. Performs complex technical, analytical and detail-oriented work independently as it relates to gaming records and activities. Recognize 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: Anti-money laundering (AML) Case Management System, Synkros system for slot and table ratings, Patron Authenticator, NeWave for electronic MTL/MIL, FileBound, and Tri-Tech.
2. Prepares detailed investigative reports for Casino Compliance Leadership review/approval and provides a recommendation as to whether a patron’s gaming or transactional activity is suspicious (thereby requiring a SAR filing or a “No-SAR” determination if more appropriate). Responsible for making written recommendations based on assessment of internal gaming data sources, external commercial data sources, internet and other sources. Makes recommendations which involves independent analytical assessment and articulation of all available researched information and exercise of judgment to include description of reason(s) or rationale for recommended courses of action.
3. Performs independent 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. Assesses information in relation to a patron’s gaming and transactional activity to evaluate any potential suspicious activity and/or money laundering risk posed by a patron. Performs independent 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 Casino gaming floor to assess whether activity involves potential money laundering, terrorist financing or other related illicit activity. (Investigations range in complexity, some may require minimal due diligence pertaining to specific activity while others may involve complex source of funds investigations involving enhanced due diligence procedures and exercise of sound judgment in recommendations to Leadership for review and approval). Responsible for escalating investigations involving highly sensitive matters, per internal policies and procedures.
4. Prepares SARs, including the writing of the narrative, which requires the ability to articulate the facts for the benefit of law enforcement, and ultimately the filing with U.S. Department of the Treasury, specifically FinCEN.
5. Assists in development of standard investigative procedures and protocols (including methodologies and typologies relating to money laundering schemes and related financial fraud schemes).
6. Performs other duties as assigned to support the efficient operation of the department.
Education/Experience/Qualifications
- High School Diploma or GED is required.
- Bachelor’s degree in Forensic Accounting, Business Administration, Criminal Justice and/or related field is preferred.
- Minimum of two (2) years of internal/external audit and/or equivalent experience required with an emphasis on regulatory matters relating to the Bank Secrecy Act and/or Anti-Money Laundering.
Certificates/Licenses/Registrations
- 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.
- Equivalent combination of education and progressive, relevant and direct experience may be considered in lieu of minimum educational/experience requirements indicated above.
- Must have experience applying and interpreting the Bank Secrecy Act and USA Patriot Act to the work environment is preferred.
- 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 have experience with multiple player tracking systems.
- Must be able to analyze accounts/transactions and identify/report on anomalies.
- Must have good report writing skills.
- Must possess proficient computer skills with the ability to use Microsoft Office Suite (i.e., Word, Excel, and Outlook).
- Must maintain the highest degree of confidentiality with respect to critical matters involving Yaamava' Resort & Casino AML Program.
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!