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 Title 31 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) filingsAssists 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 changesProvides 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 concernsEnsures timely retrieval, review, completion and filing of all Multiple Transaction Logs (MTL), Monetary Instrument Logs (MIL), and CTRAssists as needed, with coordinating the AML Committee for SAR investigation and submissionCoordinates all internal and external audit reviews and documentation preparation relating to Title 31Reviews risks associated with Title 31 including resolving compliance, internal and external audit findings and recommendationsResponsible 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 proceduresUpdates and maintains the annual Title 31 training program to ensure continual compliance with current regulations and training material reflect current practicesCoordinates annual Title 31 training including assisting department managers to ensure new hire training is completedPrepares and presents reports on the status, activities, and plans for current and future operations to the Title 31 ManagerMaintains 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 Title 31 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 regulationsEnsures confidentiality of all information pertaining to the EnterpriseImplements and assists managerial staff in the completion of all departmental Risk Analysis requirementsSupports Compliance Coordinator as neededPerforms 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 regulationsKnowledge of records management and basic accounting proceduresKnowledge of gaming operations and controlsKnowledge of Tribal MICS, Arizona Gaming Compact, TON Gaming Ordinance and IRS gaming operations, tax reporting and withholding requirementsKnowledge of Title 31 requirements and training programKnowledge of business English, proper spelling, grammar, punctuation, and basic arithmeticAbility to work as a team member and foster a positive working environmentAbility to work with timelinessAbility to communicate effectively in the English language, both verbally and in writing with team members and the general publicAbility to demonstrate outstanding guest service at all timesAbility to establish and maintain professional relationships with individuals of varying social and cultural backgrounds and with team members at all levelsAbility to maintain confidentialityAbility to analyze situations and adopt appropriate courses of actionAbility to handle multiple tasks and meet deadlinesAbility to make solid decisions and exercise independent judgmentAbility to follow oral and written instructionAbility to work independently with minimal supervisionAbility to define problems, collect data, establish facts and draw valid conclusionsAbility to read, analyze, and interpret complicated documents, such as technical journals, financial reports, and legal documentsStrong analytical and deductive reasoning skillsSkill 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.

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