Senior KYC Investigator; Corporate

Job Description

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.

• 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 investigations, including the conclusions and assessment of the BSA/AML risks; referring internally potentially suspicious activity; escalating to the Corporate AML Officer certain due diligence reviews; and recommending other appropriate action.
• Work cooperatively with Compliance, the property BSA Officers, Security, and the businesses to evaluate the risks associated with high-risk business relationships, including making recommendations with respect to a specific relationship.
• Participate in special AML due diligence reviews, investigations, and projects, as requested. Stay current on legal and regulatory BSA/AML requirements and money laundering trends, patterns and methods and the associated BSA/AML risks.
• Assist in defining, refining, implementing procedures and internal controls for the KYC Review Group.
• Review incoming KYC request for proper documentation and accuracy.
• Provide ongoing support and training for Junior Corporate Investigators.
• Ensure the overall quality, consistency; risk management and adherence to department standards are being adhered to while identifying opportunities for improvement and integration with the review process.
• Provide risk identification while reviewing KYC Investigator reports for accuracy prior to submitting them to the AML Manager.
• Recognized as a leader, investigative subject matter expert, management consultant and KYC expert; develop and maintain collaborative working relationships with operations.

• Must be 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,…