Title 31 AML/Analyst

Overview

Responsible for supporting and executing all activities of the Title31 /BSA/AML compliance program, including regulatory requirements under the Bank Secrecy Act, Office of the Foreign Assets Control (OFAC), and the USA Patriot Act. This role supports ongoing monitoring, reporting, investigations, and compliance efforts to ensure effective and efficient operation of the AML compliance program, and Title 31 compliance program.

 

This list of duties and responsibilities is illustrative only of the tasks performed by this position and is not all-inclusive.

 

MINIMUM QUALIFICATIONS:

• Must be a minimum of 21 years of age.
• Associates degree required. (Accounting, Finance, Criminal Justice, or related field preferred).
• Minimum of two (2) years of experience in AML compliance and SAR Investigations required.
• Casino gaming industry experience required.
• Required to pass a pre-employment drug screening and obtain and maintain an Osage Nation gaming license.
• Required to provide documents to show the applicant is eligible to work in the United States.
• Osage, Native American, and Veteran preference shall apply to all positions at Osage Casinos.
• Applicants must be able to perform all essential functions of job duty with or without reasonable accommodation.

Responsibilities

REGULATORY COMPLIANCE:

• Maintains excellent working relationships with other Company staff and all applicable regulatory commissions and other agencies as may be applicable to ensure compliance.
• Performs all duties in accordance with company core values, objectives of the Osage Nation, internal policies and procedures, as well, as applicable laws and gaming regulations, including but not limited to, the state-tribal compact, IGRA, MICS, ONGR, the Bank Secrecy Act, Office of Foreign Asset Control, USA Patriot Act and Privacy Act.

COMMUNICATION:

• Make efforts to keep informed of company information and communications by reviewing property bulletin boards, digital signage, and company newsletter.
• Effectively communicates concerns and information to supervisor and listens to communication from supervisor.
• Effectively relates ideas for improvements to Supervisor and management in accordance with chain of command.
• Observes and reports all unsafe behavior displayed by internal and external guests.
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DEPARTMENT OPERATIONS:

• Conducts full investigations on patrons and files timely reports of SARs with FinCEN.
• Conducts KYC monitoring, and enhanced due diligence of High-risk Patrons.
• Reviews and research casino documentation for Transactions that may result in the filing of SARs.
• Assists with the performance preliminary daily Title 31 audits as a secondary responsibility, including but not limited to the following:
• Reviewing Multiple Transactions Logs (MTLs).
• Reviewing Negotiable Instrument Logs (NILs).
• Reviewing Slot bill-in reports.
• Reviewing Slot ticket data.
• Reviewing Table rating reports.
• Reviewing all other casino system reports.
• Audits and files Currency Transaction Reports (CTRs).
• Completes daily audits of Title 31 Reports.
• Creates, distributes, and maintains exception notices and department communications of any failure to meet Title 31 regulatory guidelines.
• Performs periodic review of casino departments execution of AML functions to identify and execute additional training opportunities.
• Prepare and present relevant data or information and investigations findings, at committee and sub-committee meetings.
• Assists with responding to inquiries made by Internal/External Auditors, and other regulatory authorities about gaming operation compliance with the Bank Secrecy Act, OFAC, and the USA Patriot Act.
• Creates and distributes specified reports to various departments on a regular basis.
• Troubleshoots in system errors, and compliance questions.
• Facilitates the flow of information throughout the property by organizing and presiding over regularly scheduled meetings pertaining to Title 31.
• Ensures a maximum level of company-wide service and satisfaction in Title 31 compliance is maintained.
• Prepares detailed daily, weekly, and monthly operating or informational reports as required by the reporting management.
• Provides annual training for applicable team members as required by MICS and ONGR.
• Ensures that department managers address regulatory requirements and assists those managers with finding the operational methods needed to comply with those regulations.
• Trains and advises the Training and Development department in Title 31 training requirements for all casinos.
• Makes recommendations to leadership of changes and updates to the Title 31 compliance program.
• Assists with the periodic review of BSA regulatory requirements within all company departments to ensure compliance with Title 31 requirements, company policies, Tribal Regulations, State Compact requirements, and Federal Regulations.
• Prepares CTRs and SARs for review by the Supervisor and timely filing.
• Participates in Quarterly Title 31 Committee meetings.
• Monitors all relevant activities of the area of responsibility, to ensure that all applicable laws, rules, regulations, and controls of the organization, and the National Indian Gaming Commission (NIGC) and the Osage Nation Gaming Commission (ONGC) are understood and enforced by all applicable personnel.
• Makes recommendations regarding the development, maintenance, and implementation of internal controls necessary to ensure compliance with Title 31 requirements.
• Conducts audits of daily information to ensure compliance with Title 31, including but not limited to ensuring completion of Currency Transaction Reports by Casino and reporting of those to FinCEN (Financial Enforcement Network).
• Assists with developing, writing, and distributing Policies and Procedures for the establishment of internal controls to achieve compliance with Title 31, OFAC, and the USA Patriot Act.
• Perform compliance audits from source documents to verify that proper CTRs were filed.
• Cooperates with external auditors, compliance, and investigations.
• Performs all other related and compatible duties as assigned.
• Cooperates and communicates with all fellow employees, always exhibiting mutual respect and consistently projecting a positive, helpful image/attitude.

Qualifications

KNOWLEDGE, SKILLS, AND ABILITIES:

• Knowledge of the Bank Secrecy Act, USA Patriot Act and OFAC.
• Working knowledge of AML and compliance systems such as NICE Actimize, LexisNexis or similar platforms, with the ability to learn and adapt to internal monitoring, reporting, and case management tools.
• Accountable for the accuracy and thoroughness of Title 31, OFAC, and USA Patriot Act records and reports.
• Read, write, speak, and understand the English language. Read Company or departmental reports, newsletters, and documents.
• Perform routine and intermediate mathematical computations.
• Protect the Company’s value by keeping information confidential.
• Perform assigned tasks under limited supervision. Follow written and verbal instructions.
• Establish and maintain positive relationships with managerial staff, co-workers, guests, and the public. Work well alone or within a team.
• Communicate information and suggestions in oral and written form. Prepare written documents and complete reports as required.
• Utilize MS Office products to an intermediate skill level.
• Exercise reasonable judgment and seek guidance for decisions in a manner consistent with the essential job duties and responsibilities.
• Report problems and avoid situations that could be deemed illegal or represent a safety hazard to fellow employees or guests.
• Responds to inquiries from employees, regulatory agencies, and others.
• Travel locally, or between properties as needed.
• Maintain physical condition and stamina appropriate to performance of assigned duties.
• Update job knowledge by participating in educational opportunities; webinars, attending expos or conventions; and developing or maintaining professional networks. 

PHYSICAL DEMANDS:

• The employee is also regularly required to stand for extensive periods of time, walk, sit, and use hands to finger, handle, or feel objects, tools, or controls.
• Ability to sit, stoop, kneel, crawl, balance, or crouch while performing duties.
• Ability to use hands to finger, handle, or feel.
• Ability to use arms to reach and lift above shoulders.
• Must have normal auditory and good verbal communication.
• Ability to lift upwards of 30 pounds.
• Ability to drag, push, or pull up to 50 pounds.
• Specific vision abilities required by this job include close vision, distance vision, color vision, peripheral vision, depth perception, and the ability to adjust focus. 

WORK ENVIRONMENT:

• Work is typically performed within an office setting.
• Use computer systems and/or other devices to effectively perform job functions.
• Exposure to second-hand smoke.
• Ability to work irregular shifts, evenings, weekends, and extended hours may be required.
• The noise level in the work environment is low to moderate.
• The employee is regularly exposed to risks associated with travel between properties and back and forth to other areas as may be required due to business demands.