Job Description

SCOPE OF POSITION:

The Compliance Manager oversees all daily operations of Compliance. The Compliance Manager shall be responsible for overseeing and ensuring the thorough, timely, and accurate completion of all audits, reviews, research/investigations, filings, notifications, and preparation/retention of all documentation in compliance with all FireKeepers Casino Hotel internal controls; policies and procedures; Gaming Commission TICS; and Tribal, State and Federal regulations and laws—including, but not limited to, FireKeepers’ Anti-Money Laundering/Counter the Financing of Terrorism (AML-CFT) Compliance Program. The Compliance Manager is required to maintain complete confidentiality and discretion in discharge of responsibilities—and ensure the same of all Compliance Team Members. All duties are to be performed within the guidelines of FireKeepers Casino Hotel, Internal Control Standards and objectives.

ESSENTIAL DUTIES AND RESPONSIBILITIES:

The following is a list of the main duties and responsibilities. However, other duties may be assigned as deemed necessary by management. All duties must be performed in accordance with Tribal, Federal, and other applicable requirements, organizational specific policies, procedures and practices.

• Develops, trains, advises and supports the Compliance team.
• Evaluates performance and progress of the Compliance team and adjusts performance standards as needed.
• Coordinates, monitors and reviews the Compliance team’s compilation, research and audit of all applicable AML-CFT system and manual Multiple Transaction Logs (MTL) and Monetary Instrument Logs (MIL).
• Guides and monitors the Compliance Supervisor’s review of all AML-CFT system-generated and manually-entered Currency Transaction Reports (CTR) within the AML-CFT system. Ensures all CTR’s are complete, accurate and filed timely as required by law.
• Reviews (and prepares as needed) all Suspicious Activity Reports (SAR) within the AML-CFT system including detailed, descriptive, chronological, narratives using templates and guidelines as provided by the Director of Compliance & Analysis.
• Routinely oversees, and reviews results of, all research conducted on Activity Incident Reports (AIR) submitted by departments. Provides Director of Compliance & Analysis with feedback on potential reporting.
• Ensures use of all available internal and external information to determine if a CTR or SAR is required and provides recommendations to Director of Compliance & Analysis for SAR filing and/or reporting.
• Ensures compliance with all BSA/AML-CFT reporting requirements, including reporting deadlines, inclusive narratives, and proper identification of all parties.
• Conducts Customer Due Diligence reviews and research, using all available information, and provides recommendations to Director of Compliance & Analysis for monitoring or presentation to Committee.
• Routinely works with various departments’ management to ensure communication, comprehension and compliance with AML-CFT requirements. Provides assistance when possible and seeks guidance from Director of Compliance & Analysis as needed. Provides training and guidance to departments on AML-CFT compliance software and reporting conduits.
• Ensures documentation, in a thorough and organized manner, of all audits, decisions, processes, research results, discussions and any other pertinent data to support all determinations and actions taken or not taken by Compliance audit, Finance or the AML-CFT Compliance Committee.
• Reviews Compliance team’s identification of incidents of AML-CFT Program non-compliance and the adequacy and issuance of exception reports. Assists Director of Compliance & Analysis with communication and collaboration with Department Vice Presidents to isolate and correct chronic issues.
• Researches AML materials and media for any Gaming-related reporting requirement changes. Provides Director of Compliance & Analysis with pertinent details and coordinates training and guidance for Compliance team. Possesses a strong, comprehensive understanding of the BSA/AML-CFT Program and requirements.
• Completes, and ensures Compliance team completes, all required training, including, but not limited to, annual AML-CFT training and assessment. Enrolls in and attends various webinars, seminars, conferences, and other events/training as instructed by Compliance management to maintain current comprehension of responsibilities for compliance.
• Analyze various data analysis reports to determine whether any transactions should be the subject of a SAR review.
• Ensures the preparation of all related records for internal and external audits.
• Assists Director of Compliance & Analysis with AML-CFT Program Policy and Procedures reviews and revisions, annual training monitoring, independent testing, CDD/KYC initiatives.
• Conducts all research, preparation, documentation and reporting and coordinates with Director of Compliance & Analysis as requested.
• Ensures Compliance team develops, maintains, generates and analyzes various data analysis reports in order to determine whether any transactions should be the subject of a SAR review.
• Attends and participates in the AML-CFT Compliance Committee meetings. Maintains the highest level of confidentiality.
• Ensures the Compliance team maintains and monitors calendar(s) encompassing dates related to reviewing, researching, reporting, filing, etc. for legal, regulatory and procedural compliance and works with the Director of Compliance & Analysis to ensure all deadlines are met.
• Assists Director of Compliance & Analysis with maintenance of the SICS and Policies and Procedures for both on-premises and online operations; ensures Compliance repositories are up-to-date and organized.
• Reviews procedures for consistency and applicability and identifies potential areas of concern or improvement; communicates discoveries to Director of Compliance & Analysis.
• Receives and processes any forms or medium used for departmental requests for the creation or revision of all procedures; assists the Director of Compliance & Analysis with the review of adherence to the SICS and the applicability to operations.
• Monitors progress of requests for revision, coordinates the timely routing of requests including obtaining the necessary signatures. Prepares final documentation for Director of Compliance & Analysis review.
• Assists with the submission and tracking of all policies and procedures to the NHBP Gaming Commission (or Michigan Gaming Control Board where applicable) and informs the Director of Compliance & Analysis of delays in approval or response.
• Coordinates and cooperates with Internal Audit for the successful and mutually-satisfactory fulfillment of Compliance’s responsibilities for the SICS and procedures. Assist with clarification of compliance-related matters as they may impact Internal Audit.
• Coordinates and oversees (conducting when necessary) receipt, review, registering, processing and/or monitoring of any e-mail messages, forms, subpoena, summons and/or other medium used for notification, requests, etc.
• Evaluates and coordinates subpoena, summons and document requests, ensuring the appropriate departments are notified and all records are complete and prepared for distribution to the requesting agency.
• Assists Director of Compliance & Analysis with the coordination and communication of document requests, deadlines, responses and submissions for audits conducted by the NHBP Gaming Commission, the Michigan Gaming Control Board or other regulatory agency.
• Coordinates and cooperates with other Finance Department Managers for the successful fulfillment of Compliance’s responsibilities as the Director of Compliance & Analysis may direct.
• Assists, and coordinates with, Director of Compliance & Analysis to ensure compliance with all applicable laws, rules, regulations and controls of the company, Federal and State Tax authorities, the NHBP Gaming Commission and the Michigan Gaming Control Board.
• Ensures the highest degree of accuracy, consistency and timeliness with all documentation and communication.
• Performs other duties as assigned.
• Maintains the highest level of confidentiality.
• Responsible for maintaining a consistent, regular attendance record as outlined in the FireKeepers Casino Hotel Attendance Policy.
• Outstanding example of and a credit to FireKeepers Casino Hotel.

SUPERVISORY RESPONSIBILITIES

Carries out supervisory responsibilities in accordance with the organization’s policies and applicable laws. Responsibilities include maintaining sufficient staffing levels; interviewing, hiring, and training Team Members; planning, assigning, and directing work; appraising performance; rewarding and disciplining Team Members; addressing complaints and resolving problems.

Job Requirements

MINIMUM REQUIRED QUALIFICATIONS

An applicant’s education, training and experience must be sufficient to demonstrate that the applicant possesses the ability to successfully perform each of the essential duties and responsibilities satisfactorily. FireKeepers reserves the right to verify the sufficiency of a candidate’s education, training and competencies through the interview process, testing and methods.

The requirements listed below are generally representative of the education, experience, and skills and/or abilities required to enable one to successfully perform the essential duties and responsibilities:

Bachelor’s degree in accounting or other related field, or four (4) years AML, compliance and/or auditing experience. Two (2) years as a supervisor or lead. Must have proficient computer skills, including Microsoft Word, Excel and 10-key. Must be able to work in an intense and fast-paced environment where a high degree of concentration is necessary to perform the required job duties. Must have the ability to resolve problems/conflicts in a diplomatic and tactful manner. Must be at least 21 years of age.

GENERAL OR PREFERRED QUALIFICATIONS

A minimum of one (1) year of direct AML auditing experience is preferred. IRS reporting and compliance related experience is preferred.

LANGUAGE SKILLS

Ability to read and interpret documents such as safety rules, operating and maintenance instruction, and procedure manuals. Ability to write routine reports and correspondence. Ability to speak effectively before groups of customers or employees of organization.

MATHEMATICAL SKILLS

Ability to add, subtract, multiply and divide in all units of measure, using whole numbers, common fractions and decimal, and work with mathematical such as probability and statistical inference.

REASONING ABILITY

Ability to define problems, collect data, establish facts, and draw conclusions. Ability to interpret an extensive variety of technical instructions in mathematical or diagram form and deal with several abstract and concrete variables.

PHYSICAL & ENVIRONMENTAL DEMANDS:

The physical demands described here are representative of those that must be met by a Team Member to successfully perform the essential functions of this job.

Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.

While performing the duties of this position, a Team Member is regularly required to talk or to hear. The Team Member is also regularly required to stand, walk, sit, and use hands to handle or feel objects, tools or controls. A Team Member is occasionally required to reach with hands and arms, and to sit; climb or balance; and stoop, kneel, crouch or crawl. Specific vision abilities required by this job include close vision, distance vision, color vision, peripheral vision, depth perception and the ability to adjust focus.

Work is performed throughout all areas of the facility where the noise level varies from quiet to loud depending upon business. Must be able to work in a smoke filled environment.

INDIAN PREFERENCE

Indian preference will be applied in the selection of qualified applicants in accordance with the NHBP Indian Preference in Employment Code, which affords employment preferences to NHBP Tribal citizens, parents or spouses of NHBP citizens and other Native Americans. For purposes of this preference, NHBP law defines "Native American" as: (a) an enrolled member of any other federally-recognized Indian tribes; (b) an enrolled member of a Canadian Indian tribe or First Nation; or (c) an enrolled member of the Grand River Band of Ottawa Indians or the Burt Lake Band of Ottawa/Chippewa Indians.

FireKeepers Casino Hotel reserves the right to make changes to the above job description as necessary.