Title 31 Analyst

Under the direction of the Manager, BSA Compliance, the Title 31 Analyst ensures the San Manuel Entertainment Authority is compliant with the Bank Secrecy Act (BSA), the Patriot Act and requirements of the Office of Foreign Asset Control (OFAC) as it pertains to casinos, by reviewing, auditing, investigating, analyzing and filing the Currency Transaction Reports (CTRs) that are received from various data sources that capture transactional activity. The Title 31 Analyst requires a high-level of autonomy to complete tasks and independently analyze tracking logs for compliance including, but not limited to investigating and correcting errors and omissions from the tracking logs. The Title 31 Analyst partners with department management enterprise-wide by using independent judgment and makes recommendations via reports to ensure any breaches are properly addressed in the internal controls as it concerns the tracking of Casino patrons under the BSA. The Title 31 Analyst conducts preliminary research, analyzes facts, and prepares an Initial Due Diligence Report for Senior Management. They identify suspicious activity incidents and prepare necessary documentation for submission to the U.S. Treasury Department. They also collaborate with other functions, upholding the Tribe's vision, mission, and values.

Essential Duties & Responsibilities

1. Reviews, compiles, and administers oversight of audited Currency Transaction Reports (CTR) by reconciling the correct threshold amount to meet the mandatory required fields in order to file with the regulatory agency. Makes recommendations involving analytical assessment of all available information and provides directions or recommended course of action for complex transactions. Ensures the adherence to procedures by auditing financial transactions from various reports and tracking logs to issue exceptions to the respective department when the BSA/AML compliance procedures are not in compliance.

2. Performs, measures, and analyzes statistical and complex technical data to monitor trends relating to records of gaming operations by assessing whether activity meets regulatory and internal policy criteria, processes and resources for review and audit of Currency Transaction Reporting (CTR’s) to the regulatory agency to ensure transactions and patron information is current and accurate.

3. Gathers, interprets, and analyzes information from multiple players tracking systems, including but not limited to Synkros, jackpot reporting systems, credit card and check cashing systems Multiple Transaction Logs, Negotiable instrument log, and Synk31 to review, audit and file CTR’s currency transaction reports. Provides ongoing assistance to the BSA/AML investigations team as relates to IDD, unusual activity, analysis, CTRs, and/or daily aggregation audits.

4. Performs research using proprietary commercial databases and open source (internet) and social media sites to obtain information relevant to a patron’s identification, occupation, residency, and possible negative news (if negative news is identified, information is reported to BSA investigations team via SAI).  In addition, uses above information in conjunction with casino systems to analyze and report gaming activity, trends which may include previously filed SARs, CTRs, and SAIs and all available information to complete an IDD report or for further action on a CTR report. 

5. Determines whether there is Agent Activity, and if so, creates an analysis and CTR to file discreetly with regulatory agency. 

6. Assists in quality process development of standard auditing desk procedures and protocols to provide Casino Compliance information that is reviewed and audited for filing accurate CTRs.

7. Performs other duties as assigned to support the efficient operation of the department.

Education/Experience/Qualifications

• Bachelor’s degree in Forensic Accounting or Finance, Business Administration and/or related field required.

• Minimum of two (2) years of progressive internal/external auditing experience and/or equivalent experience required with an emphasis on regulatory matters relating to the Bank Secrecy Act and/or Anti-Money Laundering; Currency Transaction Report experience required. 

• Related, relevant, and/or direct experience may be considered in lieu of minimum educational requirements indicated above.

• Experience applying and interpreting the Patriot Act to the work environment preferred.

• Demonstrate thorough working knowledge of the Anti-money Laundering policies and procedures for Title 31 transaction reporting departments (i.e., Cage Operations and Table Games), preferred.

• Must be able to analyze accounts/transactions and identify/report on anomalies.

• Must possess proficiency in data analysis and computer skills with the ability to use Microsoft Office Suite (MS) (i.e. MS Word, Excel, and MS Outlook).

• Relevant certifications such as Certified Anti-Money Laundering Specialist (CAMS) or Certified Fraud Examiner (CFE) are a plus.

Certificates/Licenses/Registrations

• At the discretion of the San Manuel Tribal Gaming Commission, you may be required to obtain and maintain a gaming license.

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!