License & Registration
First, which group are you in?
All employees of a casino have to be licensed or registered. There are different rules and regulations for different groups of employees. The first thing to do is to determine which of the following three groups would include you:
Key Gaming Employee
There are two levels of key gaming employee, executive and standard:
Executive level key employees include: assistant general manager, audit manager, chief internal audit officer, casino gaming manager, chief financial officer, chief of security, managers or supervisors of security employees, general manager, chief surveillance officer manager, chief compliance officer, principal executive officer, principal operating officer, principal accounting officer, chief information officer, etc.
Standard level key gaming employees include: controller; electronic gaming device or slot machines manager; human resources manager; information technology manager; pit boss; shift supervisor of table games, of a slot department, credit department, security, surveillance, accounting department, cage, or player development; credit manager; cage manager; hotel manager; entertainment director; food & beverage manager; other managerial employees not included in the executive level but who are empowered to make discretionary decisions which impact gaming establishment operations.
All key gaming employees, executive and standard, have to be licensed.
Anyone whose employment relates directly to a gaming establishment, for example:
• Dealers, croupiers, boxpersons, floorpersons, slot attendants, gaming hosts, shills,
• Cashiers, change personnel, clerks, count room personnel, data processing personnel, internal audit and accounting personnel who deal with gaming activity,
• Anyone connected to the operation or maintenance of a slot machine or game (whether employed by the casino or a vendor) including mechanics and technicians for computers, table game devices, or other machines,
• Anyone authorized to grant credit under $5,000, to give away complimentary services, to act like a junket representative, or to issue promotional play, including promotional play supervisors,
• Anyone with security administrator access to a slot machine tracking system,
• Security personnel, including guards and game observers, or an employee with knowledge of security procedures.
All gaming employees have to be licensed.
Gaming Service Employee
Everyone else. Anyone who works in a gaming establishment and is not classified as a key gaming employee or a gaming employee as noted above. The “gaming establishment” would include not only the gaming area, but also any other nongaming structure related to the gaming area including hotels, restaurants, retail shops, or other amenities. This group would include:
• Food servers, wait staff, bartenders, bus-persons;
• Chefs, cooks, food preparers, dishwashers;
• Hotel staff including managers, front desk staff, housekeepers, bellhops, pool attendants;
• Retail shop clerks and managers;
• Maintenance, groundskeepers, and facilities staff.
Gaming service employees have to be registered.
Will I be subject to a background check or a criminal records check?
Yes. In order to insure the integrity of gaming in Massachusetts, everyone who works in a casino will have to go through a background check including a criminal records check. Whether applying for a license or registration, everyone will have to:
• Disclose any past arrest, indictment, charge, or conviction;
• Disclose all governmental financial liens or judgments, including state tax liens, delinquent child support obligations, defaulted student loans, unemployment judgments, unpaid motor vehicle surcharges, and/or welfare judgments;
• Consent to fingerprinting, photographing, and the supplying of handwriting samples;
• Authorize the release any and all information about you from all courts, law enforcement agencies, probation departments, selective service boards, employers, educational institutions, banks, financial and other institutions and all governmental agencies.
Can I work in a casino if I have been convicted of a crime?
Anyone convicted of a felony or other crime involving embezzlement, theft, fraud, or perjury is automatically disqualified from working in a casino. If someone is disqualified for this reason and the conviction occurred ten or more years ago, there is a process to demonstrate rehabilitation.
Will everything on my criminal record count against me?
Only a conviction (a finding of guilty) will be considered an automatic disqualifier. Other dispositions such as pending, continued, continued without a finding, dismissed, nolle prosequi, not guilty, restitution, terminated, etc. will not be considered automatic disqualifiers. Similarly, for offenses committed when a minor, the disposition of delinquent (the equivalent of a guilty conviction for juveniles) will not be considered an automatic disqualifier. But, all such incidents will be considered as part of the overall evaluation of the applicant’s character.
Criminal records that have been sealed will not be considered at all.
When it doubt, it is a good idea to have your CORI checked before applying for a job, a license, or a registration. It is very important to be completely truthful when filling out the application.
Can I be denied a license or registration to work in a casino because of my past activities?
The Commission shall deny a license or registration to anyone who has:
• been convicted of a felony or other crime involving embezzlement, theft, fraud or perjury;
• submitted an application that intentionally contains false or misleading information;
• committed prior acts which have not been prosecuted or in which the applicant was not convicted but form a pattern of misconduct that makes the applicant unsuitable; or
• has affiliates or close associates that would not qualify for a license or whose relationship with the applicant may pose a problem.
What other factors will be considered?
In determining whether an applicant for a key gaming or gaming license is suitable, the commission will consider the applicant’s overall character including:
• the integrity, honesty, good character and reputation of the applicant;
• the financial stability, integrity and background of the applicant;
• whether the applicant has a history of compliance with gaming licensing requirements in other jurisdictions;
• whether the applicant, at the time of application, is a defendant in litigation;
• whether the applicant has been convicted of a crime of moral turpitude;
• whether and to what extent the individual has associated with members of organized crime and other persons of disreputable character;
• the extent to which the individual has cooperated with the background investigation;
• and, for vendors, the integrity, honesty, and good character of any subcontractor.
These same factors may be considered for applicants for registration as a gaming service worker.
When should I apply for a license or registration?
Once you get a job offer from the casino.
When can I start working?
For a gaming service employee, once the application is deemed to be “administratively complete” a registration will be issued. That should take only a few days. But, if the background investigation and evaluation later determines that an individual is unsuitable, the registration will be revoked and the individual will have to stop work.
For a key gaming employee, background investigation and evaluation can take weeks or months to complete. In this case the commission may issue a temporary license that will be good for up to six months. If needed, a six month extension could be granted.
What will it cost to get a license or registration?
• For a key gaming employee: $1,000 plus all expenses
• For a gaming employee: $300
• For a gaming service employee: $75
The hiring casino could make arrangements to defray these expenses.
Why will the Massachusetts Gaming Commission do a background investigation on each applicant for employment?
The Massachusetts gaming law, Chapter 23K, gave the commission the responsibility of ensuring the honesty and integrity of gaming in Massachusetts. Towards this end, the commission has been empowered to investigate the background of potential employees of a gaming establishment to ensure that the individuals have the character, reputation, integrity and general fitness to warrant the belief by the commission that the employees will act honestly, fairly, soundly and efficiently.
How much of my criminal history am I required to disclose?
All of it. You have to disclose any past arrest, indictment, charge, or conviction. It is important to be completely truthful. No applicant, licensee, or registrant should willfully withhold information or knowingly give false or misleading information to the commission. Doing so will cause you not to get a license or to lose one if you have it. Similarly, any licensee or registrant arrested or convicted of a crime who fails to report the charges or the conviction to the commission can have their license or registration suspended or revoked.
If I have been convicted of a felony or one of the other crimes, how can I show that I am rehabilitated?
If you are turned down for a license as a gaming employee or a registration as a gaming service employee and the incident took place more than ten years ago -- then the commission may, at its discretion, issue a license or registration if you can provide proof of rehabilitation. In evaluating your request, the commission will consider the following:
• the nature and duties of the position you are seeking;
• the nature and seriousness of the offense or conduct;
• the circumstances under which the offense or conduct occurred;
• the date of the offense or conduct;
• your age when the offense or conduct was committed;
• whether the offense or conduct was an isolated or repeated incident;
• any social conditions which may have contributed to the offense or conduct; and
• any evidence of rehabilitation, including recommendations and references of persons supervising you since the offense or conduct was committed.
Key gaming employees cannot offer proof of rehabilitation for a felony or other crime involving embezzlement, theft, fraud, or perjury. Key gaming employees may offer proof of rehabilitation for a crime of moral turpitude.
I already have a gaming license from another state; will I need to get a new one for Massachusetts?
As of right now, yes. The Massachusetts Gaming Commission has not established minimum requirements for reciprocal licensing for out-of-state gaming employees.
If I am terminated or resign, what happens to my gaming license?
The commission sets the term for licenses and registrations. The commission also has the authority to suspend or revoke a license and would most likely require notification of a change in employment status. The license holder has the continuing duty to provide information and not withhold information from the commission.