Sr. BSA Investigator
Posted 10 days ago
Under the direction of the Senior Manager, Compliance, the Senior BSA Investigator/Analyst will ensure that the San Manuel Entertainment Authority is in compliance with the Bank Secrecy Act [31 CFR §1021.320], the Patriot Act and requirements of the Office of Foreign Asset Control as it pertains to casinos by investigating unusual activities reported from the SMC gaming floor and activity derived from data analytic reports.. The Senior BSA Investigator/Analyst will perform in-depth analysis of facts and related information. Using the analysis conducted, they will further prepare detailed analytical reports for senior management that include recommended courses of action based on their analysis and exercise of sound judgment. In certain instances, the Senior BSA Investigator/Analyst will prepare Suspicious Activity Reports (SARs) for filing with the U.S. Department of the Treasury as well as review the work of others for quality, accuracy and completeness.
Essential Duties & Responsibilities
- Performs 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. This will require the exercise of judgment based on prior experience, training and education. Gathers, interprets, and analyzes information from multiple systems, including but not limited to; Table Manager, jackpot reporting systems, EZ Pay Bills, credit card advances, check cashing systems, electronic Multiple Transaction Logs, Guest Service Patron Management and New Wave.
- 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. The BSA Investigator/Analyst will assess this information in relation to a patron's 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. Investigates Unusual Activity Reports (UARs) received from the casino gaming floor to assess whether the activity involves potential money laundering, terrorist financing or other related illicit activity.
- 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. These investigations will require, at minimum, enhanced due diligence procedures and the exercise of sound judgment in recommendations to senior management.
- Escalates investigations involving highly sensitive matters per internal policies and procedures.
- Prepares detailed investigative reports for 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.
- Under the direction of management, prepares SARs including narratives for filing with the U.S. Department of the Treasury.
- 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.
- Performs, as needed, supervisory type functions in the form of reviewing the work of others for quality, accuracy, and completeness. In addition, incumbent will provide advice and guidance to other BSA investigators on investigative matters.
- Performs the task of reviewing and electronically filing approved SARs with FinCEN.
- Perform other duties as assigned to support the efficient operation of the department.
- Bachelors Degree is required. Degree in Business, Criminal Justice, Forensic Accounting or a related field is preferred.
- Three (3) years of Anti-money laundering or other related investigative experience is required.
- Five (5) years of Anti-money laundering experience is preferred.
- Casino experience is a plus.
- Equivalent combination of education and experience may be considered in lieu of degree.
- Must have strong working knowledge of the BSA/AML and suspicious activity regulatory requirements.
- 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. Advanced excel skills (e.g., use of pivot tables) is preferred.
- Must possess excellent report writing skills and verbal communication skills.
- Must have the ability to work independently with minimal supervision.
- Certified Anti-Money Laundering Specialist through certification via ACAMS is preferred.
- At the discretion of the San Manuel Tribal Gaming Commission you may be required to obtain and maintain a gaming license.