Senior KYC Investigator; Corporate

Overview

The Senior KYC Investigator will be responsible for performing holistic due diligence reviews in support of the Corporate KYC and BSA/AML Policies and Procedures. Conduct detailed initial, periodic and complex investigations when certain events occur that may raise the risk profile for certain business relationships. Specifically, gathering, executing, and evaluating high risk patron indicators including verifiable Source of Funds (SOF), deep dive analytics, multi-year lookbacks, inter-casino 314(b) coordination and documentary verification to support risk-based decisions.

Findings will be organized, clearly documented with proposed recommendations and presentations to AML/KYC Leadership for review.

• Mustbe 21 years of age or older.

• The ideal candidate has advanced knowledge of BSA/AML requirements in the gaming sector, CTR/SAR standards, 314(b) protocols, and a proven ability to synthesize complex financial and patron play data into clear risk narratives and recommendations.

• Ability to read, analyze, and interpret gaming statutes, rules, and regulations. Ability to analyze information, problems, situations, and procedures from an operational perspective, identify any relevant concerns, and formulate or provide input for solutions.

• Ability to manage multi-faceted projects to a successful conclusion.

• Ability to read, write, speak, and understand English. Ability to respond to inquiries or requests from regulatory agencies.

• Proficient in Microsoft Office programs. (Excel, Word, etc.)

• Proficient in enterprise player systems, Central Credit, transactional data tools, and case management platforms.

• Ability to uphold and demonstrate the highest level of integrity in all situations and recognize standards required by a regulated business.

• Additional Requirements:

• Knowledge and experience in the AML/BSA, gaming compliance, or investigative field.

• Knowledge of AML laws and regulations, including the BSA, customer due diligence, enhanced due diligence, and the identification, investigation and reporting of suspicious activity.

• Experience in U.S. Banking industries, Gaming, or KYC Customer Identification Programs or other financial sector.

• An understanding of money laundering issues, trends, and schemes, and of effective measures to prevent and detect money laundering.

• Strong investigative skills in the areas of money laundering, financial transactions, terrorist financing and/or fraud.

• The ability to work as part of a collaborative team.

• Strong written and oral communication and presentation skills.

• Strong decision making and analytical abilities.

• Triage high risk patron cases where source of funds (SOF) does not clearly support level of play; define investigative scope, data sources, and stakeholders.

• Assess seed money reasonableness relative to initial deposit/buy-in from first rated play, observed play and subsequent bankroll movement.

• Conduct cash-in/ cash-out activity reviews.

• Compile yearly and life-to-date enterprise win/loss by property including identified trend commentary.

• Follow an investigative plan and timeline for each case; maintain case level documentation and clear work papers.

• Draft concise risk narratives and SOF conclusions (supported/partially supported/not supported) with clear escalation notes and recommended actions

• Conduct due diligence reviews of higher-risk business relationships, event-driven due diligence reviews, and periodic due diligence reviews, including reviewing and researching internet, press, and public records sources and commercial databases; screening individuals and related parties to identify Politically Exposed Persons, OFAC matches and negative news; and reviewing and analyzing internal casino records and information and transaction data from other sources.

• Assist the suspicious activity and due diligence review functions, including Compliance, the property BSA Officers and gaming operations, Corporate Security, and Surveillance, in routine and complex investigations and in determining whether to recommend filing an SAR and/or whether to take other appropriate action.

• Analyze, evaluate and document the results of due diligence reviews and…