Money Laundering Reporting Officer Supervisor

OVERVIEW

The Casino Money Laundering Reporting Officer (MLRO) monitors day-to-day compliance of the Casino ensuring timely and accurate reporting to the FIU, reporting compliance exceptions noted to the responsible department heads for corrective action, and reporting to the Casino’s Money Laundering Compliance Officer (MLCO) and Compliance Committee for additional monitoring, when required. The Reporting Officer is also a liaison with the External Compliance Auditors and the Regulators charged with the supervision, enforcement, and oversight of the AML/CFT State Ordinance.

Overall responsibilities:

Filing of unusual/subjective transaction reports to the FIU, as well as ensuring that Internal controls and audit procedures within the Casino are followed in accordance to the Marriott International Standard Operating Procedures (SOP), to The Casino at The St. Regis Aruba Resort's Local Operating Procedures (LOSP’s), the Nevada Minimum Control Standards (MICS), the AML / CFT State Ordinance, and the AML/CFT Compliance Program.

Check figures, postings, and documents for accuracy. Organize, secure, and maintain all files, records, cash and cash equivalents in accordance with policies and procedures. Record, store, access, and/or analyze computerized financial information. Classify, code, and summarize numerical and financial data to compile and keep financial records, using journals, ledgers, and/or computers. Prepare, maintain, audit, and distribute statistical, financial, accounting, auditing, or payroll reports and tables. Complete period-end closing procedures and reports as specified. Prepare, review, reconcile, and issue bills, invoices, and account statements according to company procedures. Follow-up and resolve past due accounts and vendor invoices until payment in full is received or resolved.

Coordinate tasks and work with other departments; serve as a departmental role model or mentor; assign and ensure work tasks are completed on time and that they meet appropriate quality standards. Report work related accidents, or other injuries immediately upon occurrence to manager/supervisor. Follow all company policies and procedures; ensure uniform and personal appearance are clean and professional; maintain confidentiality of proprietary information; protect company assets. Speak with others using clear and professional language; prepare and review written documents accurately and completely; answer telephones using appropriate etiquette. Develop and maintain positive working relationships with others; support team to reach common goals; listen and respond appropriately to the concerns of other employees. Move, lift, carry, push, pull, and place objects weighing less than or equal to 10 pounds without assistance. Perform other reasonable job duties as requested by Supervisors.

Functions & duties:

• Approach every guest and employees in a friendly, service-oriented manner, using clear, appropriate and professional language
• Maintain regular attendance in compliance with The St. Regis Aruba Resort standards, as required by scheduling will vary according to the needs of the hotel and casino
• Maintain high standards of personal appearance and grooming, which include wearing the proper uniform and nametag when working
• Comply at all times with The St. Regis Aruba Resort and regulations to encourage safe and efficient hotel operations and casino operations
• Support all co-workers and treat them with dignity and respect.
• Assist the Casino MLCO on the development and implementation of AML/CFT compliance-related policies and procedures throughout the Casino
• Consult with the Casino MLCO on a regular basis and report any risk or irregularity immediately
• Advise Department Heads on the implementation/interpretation of the AML/CFT compliance policies and procedures
• Provide training on AML/CFT compliance related topics, policies, or procedures
• Draft management reports regarding AML/CFT compliance operations and progress
• Review compliance with policies and procedures to AML/CFT compliance
• Verify if Customer Due Diligence (CDD) logs were completed for all Patrons whose transactions reached the monitoring threshold during the Gaming Day
• Reviewing the CDD assessment of each department for proper completion and all of the other departments and reports used to identify possible Unusual Transactions for determining whether an Unusual Transaction has occurred, typically involving an Objective indicator, or is suspected and requires additional investigation, typically involving a Subjective indicator.
• Document instances of non-compliance observed and attempt to obtain any missing information. Complete an Exception Notice when exceptions are noted during the daily review.
• Review and monitor high risk patrons which require enhanced due diligence, including Politically Exposed Persons (PEP’s)
• Review the daily Risk Assessment of new patrons for possible SDN/PEP matches
• File Unusual Transaction Reports pursuant to the State Ordinance within the stipulated time frame.
• Document the date of occurrence and/or determination of the unusual transaction, along with evidence that the Report was filed timely.
• File copies of the Unusual Transaction Reports with the daily paperwork and keep for a minimum of ten years in compliance records
• Manages relationships effectively post disclosure to avoid tipping off any third parties
• Keep all information acquired, requested or non-requested, strictly confidential
• Monitor compliance systems to ensure their effectiveness
• Keep informed regarding trends in the area of AML/CFT trends, and best practices and assess the potential impact of trends on Casino processes
• Provide feedback and recommendations to improvements in communication, monitoring, or enforcement of AML/CFT Compliance standards
• Advise on the development or use of reporting tools
• Ensure that the internal controls are followed at all times, by following the Marriott International SOP for casinos and The Casino at The St. Regis Aruba Resort LSOP’s.
• Record, store and/or analyze audit information using property SOP for casinos
• Responsible for checking the activities from the previous and current day for the casino operations
• Responsible for overseeing, checking, reporting and approving of the daily MOT/CTR activities/transactions
• Other duties as required

PREFERRED QUALIFICATIONS

• Education: High school diploma or G.E.D. equivalent.
• Related Work Experience: At least 1 year of related work experience.
• Supervisory Experience: No supervisory experience.
• License or Certification: None