Position Summary
Under direct supervision of the Title 31 Manager, oversees all Bank Secrecy Act (Title 31) processes including reporting requirements that involve daily analysis and interpretation of customer financial transactions conducted. Maintains the Anti Money Laundering (AML) Program and ensures follow up and corrective action for any violations therein. Coordinates with all departments on all Title 31 compliance issues.
This list of duties and responsibilities is illustrative only of the tasks performed by this position and is not all-inclusive.
Essential Duties & Responsibilities
Responsible for ensuring compliance with the (AML) Program
Assists in developing, implementing and maintaining, with the input of the Revenue Audit Manager, all policies and procedures for Title 31; this includes assisting with maintaining of the AML Program and overseeing the processes of the daily audit, Currency Transaction Reports (CTR) filings and Suspicious Activity Report (SAR) filings
Assists with the annual review of the AML program to determine the impact and effectiveness of internal controls, provides recommendations for enhancement, and/or evaluates proposed program changes
Provides follow up with other departments to ensure compliance with the AML Program, associated applications and other Title 31 related issues; interacts with various departments to answer Title 31 related routine questions and concerns
Ensures timely retrieval, review, completion and filing of all Multiple Transaction Logs (MTL), Monetary Instrument Logs (MIL), and CTR
Assists as needed, with coordinating the AML Committee for SAR investigation and submission
Coordinates all internal and external audit reviews and documentation preparation relating to Title 31
Reviews risks associated with Title 31 including resolving compliance, internal and external audit findings and recommendations
Responsible for maintaining a structured and secure record retention system for all Title 31 related documentation and audit findings/responses
Maintains appropriate documentation on incidents, findings, recommendations and requests for information as required by policies and procedures
Updates and maintains the annual Title 31 training program to ensure continual compliance with current regulations and training material reflect current practices
Coordinates annual Title 31 training including assisting department managers to ensure new hire training is completed
Prepares and presents reports on the status, activities, and plans for current and future operations to the Revenue Audit Manager
Maintains effective working relationships between Title 31 staff and Tohono O’odham Gaming Enterprise (TOGE) management/administration, internal/external audit, Tohono O’odham Gaming Office (TOGO), Arizona Department of Gaming (ADOG), National Indian Gaming Commission (NIGC), and Internal Revenue Service (IRS)
Reports to the Revenue Audit Manager any failure to comply with any of the provisions of the Tribal Minimum Internal Control Standards (MICS), Arizona Gaming Compact, Tohono O’odham Nation (TON) Gaming Ordinance and any other applicable laws and regulations
Ensures confidentiality of all information pertaining to the Enterprise
Implements and assists managerial staff in the completion of all departmental Risk Analysis requirements
Supports Compliance Coordinator as needed
Performs other duties as required
Minimum Qualifications
Education And Experience
Bachelor’s Degree in Business Administration or Accounting plus three (3) years’ experience in a banking institution or casino gaming environment with emphasis on Title 31 and AML regulations, two (2) years of which must demonstrate strong analysis experience; or an equivalent combination of education and experience. Will be required to pass an Excel test. Must be 18 years of age or older. No felony, theft or stealing convictions. Must be able to pass a pre-employment drug/alcohol screen, background investigation, obtain and maintain a gaming license.
Knowledge, Abilities, Skills, And Certifications
Knowledge of federal, state, and Indian gaming regulations
Knowledge of records management and basic accounting procedures
Knowledge of gaming operations and controls
Knowledge of Tribal MICS, Arizona Gaming Compact, TON Gaming Ordinance and IRS gaming operations, tax reporting and withholding requirements
Knowledge of Title 31 requirements and training program
Knowledge of business English, proper spelling, grammar, punctuation, and basic arithmetic
Ability to work as a team member and foster a positive working environment
Ability to work with timeliness
Ability to communicate effectively in the English language, both verbally and in writing with team members and the general public
Ability to demonstrate outstanding guest service at all times
Ability to establish and maintain professional relationships with individuals of varying social and cultural backgrounds and with team members at all levels
Ability to maintain confidentiality
Ability to analyze situations and adopt appropriate courses of action
Ability to handle multiple tasks and meet deadlines
Ability to make solid decisions and exercise independent judgment
Ability to follow oral and written instruction
Ability to work independently with minimal supervision
Ability to define problems, collect data, establish facts and draw valid conclusions
Ability to read, analyze, and interpret complicated documents, such as technical journals, financial reports, and legal documents
Strong analytical and deductive reasoning skills
Skill in operating gaming machines, business computers and office machines in a Windows environment, specifically Word, Excel, Access, and presentation software (such as PowerPoint).
Physical Demands
While performing the duties of this job, the team member regularly is required to sit and stand; use hands to finger, handle, or feel; reach with hands and arms; and talk or hear. The team member frequently is required to walk. The team member occasionally is required to stoop, kneel, crouch, or crawl. The team member must occasionally lift and/or move up to 25 pounds.
Work Environment
Work is generally performed in an office and casino setting with exposure to second-hand smoke and a high noise level. Evenings, graveyards, holidays and/or weekend work may be required. Extended hours and irregular shifts may also be required.