Maryland Live! Casino - Title 31 Coordinator
This little gem was discovered by a friend on the DCJobs website (thanks!). The announcement is pasted below in case the link goes bad.
Assist the Title 31 Compliance Officer in maintaining the Title 31 Compliance program to ensure compliance with applicable Federal and State gaming regulations. Responsible for understanding and complying with Title 31, Office of Foreign Asset Controls (OFAC) and Anti-Money Laundering (AML) regulations and requirements for Maryland Live! Casino. Assist with the daily Title 31 compliance operation to include but not limited to all reporting requirements of the Title 31 program. In addition, the incumbent in this position is responsible to promote positive guest relations through prompt, courteous and efficient service.
DUTIES AND RESPONSIBILITIES (*ESSENTIAL FUNCTIONS)
*Assist the Title 31 Compliance Officer in overseeing, process and ensuring accuracy of Title 31 related forms completed by casino staff.
*Ensure timely and accurate submission of Title 31 required document filings.
*Maintain all regulated paperwork and postings.
*Monitor and review all Title 31 operational areas and assist in the drafting of sound, effective and operationally efficient internal control procedures that comply with all applicable laws and regulations.
*Assist the Title 31 Compliance Officer with investigating reported suspicious activity as related to Title 31.
Inform the Title 31 Compliance Officer of potential non-compliance issues promptly and appropriately.
Ensure all team members are in compliance for all Title 31 programs by monitoring team member Title 31 training and assisting departments in meeting training requirements for successful and timely completion.
Assist the Title 31 Compliance Office in drafting written responses to internal and external Title 31 audits.
Provide any other Title 31 support to casino departments and functions as needed.
Ensure full compliance with departmental Internal Controls, policies, procedures and regulations.
Other duties as assigned.
One (1) to two (2) years of experience with Title 31 (Bank Secrecy Act), Anti-Money Laundering regulations, in a casino or banking environment.
Working knowledge of all applicable Title 31/Anti-Money Laundering, law and regulation, gaming audits and casino operations.
Ability to use standard office equipment and computer proficiency in Microsoft Office including: Word, Outlook, Excel, Power Point and Access and 10-key calculator.
Ability to respond promptly to common inquiries, complaints and/or requests from various internal and external parties in a professional manner.
Ability to write routine reports and correspondence.
Ability to communicate effectively with our guests and all levels of team members within the casino.
Ability to solve practical problems and deal with stress.
Ability to read and interpret documents such as internal controls and manuals.
Ability to deal with a variety of concrete variables in situations where only limited standardization exists.
Ability to interpret a variety of data provided in written, oral, diagram or schedule form.
Ability to maintain high standards of professionalism, integrity and discretion in handling confidential information.
Ability to handle multiple priorities in an interruptive environment.
PHYSICAL REQUIREMENTS/WORKING CONDITIONS
Ability to work irregular hours and extended shifts including late nights, early mornings, weekends and holidays.
Ability to sit 70%, stand for 20%, and walk and/or climb stairs 10% of the time.
Must be able to read, understand and speak English clearly.
Must have excellent dexterity and able to write legibly.
I thought I would start with this job announcement because it is both not something I would be applying for myself and replete with points to discuss.
So, first, what makes this job announcement a tad discriminatory? Try a guess. Like i told you above, it would be subtle. The ad actually looks pretty good until you get to the PHYSICAL REQUIREMENTS/WORKING ENVIRONMENT section, which says that a good candidate should be able to "climb stairs" 10% of the time, and should also have "excellent dexterity" in order to write legibly. The mentions of climbing stairs implicitly excludes people with mobility impairments who cannot take the stairs. The dexterity requirement explicitly excludes people with poor hand motor skills and dexterity. By asserting these qualities should be possessed by the ideal candidate, the job announcement is discriminatory against people with certain physical disabilities.
Sometimes it is not easy to discern why an employer includes a particular requirement. Here, it seems clear though. The employer wants someone who can take good notes and move about the office like you would expect anyone else (think getting files, conferring with colleagues, etc.). The employer just expressed its wish in a discriminatory manner. It probably didn't cross the HR director's mind.
However, we do know that the HR director or hiring manager behind this announcement gave SOME thought to discrimination and non-discrimination law. DUTIES AND RESPONSIBILITIES is followed by *ESSENTIAL FUNCTIONS, which means that the duties are actually divided into essential and non-essential functions of the job, with the essential stuff denoted with an asterisk. For those of you who don't know, "essential functions" is a term of legal significance. It began with the Americans with Disabilities Act (ADA), which says that employers may not discriminate against qualified people with disabilities. Over time, the courts had to decide what "qualified" actually meant. According to the Equal Employment Opportunity Commission, whose job it is to investigate allegations of discrimination under Title I of the ADA,
An individual with a disability must also be qualified to perform the essential functions of the job with or without reasonable accommodation, in order to be protected by the ADA. This means that the applicant or employee must:
satisfy your job requirements for educational background, employment experience, skills, licenses, and any other qualification standards that are job related; and
be able to perform those tasks that are essential to the job, with or without reasonable accommodation. Source: (http://www.eeoc.gov/facts/ada17.html)
So basically, the essential functions of a job are the things that you must be able to do with or without an accommodation in order to be protected under the ADA. In other words, you cannot be fired from you job for not being able to do something marginally related to the purpose of your position.
The positive thing here is that the person who wrote this job announcement had at least some understanding that the ADA plays a role here. At the very least, the employer has a good attorney - an employer stating at the outset what it believes the essential functions of a job are is MUCH better off than an employer trying to explain what it thought the essential functions were after being sued for employment discrimination.
There's more to discuss here, but this post is too long, and there are plenty of great job announcements out there to look at.
