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Course description

Like it or not, cannabis banking is here to stay.  Social stigmas are changing, political winds are shifting, and tax coffers are burgeoning.   Financial institutions are taking note, and eyeing entirely new types of profitable banking relationships.

How can banks and credit unions enter this unchartered (and still federally illegal) territory?  Can it be done in a way that keeps board members, shareholders, customers, and employees happy?  More importantly, can it be done in a way that keeps regulators and examiners happy?!  (After all, if they aren’t happy, nobody will be.)

Yes.  It is certainly a balancing act – one that must be handled with eyes wide open and with much planning – but it can be done.  First, you need to get an idea of what you are even dealing with before you can move into real planning and implementation.  Most bankers don’t have a clue about cannabis, and a crash course is critical.  These “Top Ten Big Cs” are crucial considerations:

  1. Cannabis: What exactly are we talking about?  Marijuana; hemp, CBD?  What is the difference, anyway?
  2. Compliance:  With what, exactly?  Federal, State, Local?
  3. Convictions:  Will your Board, management, employees, and customers accept your bank’s involvement in the cannabis industry?
  4. “Cole Memos”:  Both of them, and what they mean to you
  5. Cash:  In all its smelly (or not?), voluminous, AML-related glory
  6. CTRs and SARs:  Special considerations
  7. Customers:  You say you don’t bank cannabis customers yet?  Sorry to break it to you but: Yes, you do.  Right now.  And they carry a lot of baggage.  Once you offer a cannabis banking program, they will arrive with loads of issues to work through!
  8. Cards:  Surprising compliance traps when it comes to debit / ATM cards and cannabis
  9. Cost:  Yours and theirs – more than monetary
  10. Controls:  From risk assessments to transparency and daily oversight – who does what, when, and how?
  11. (Bonus!) Crystal ball:  What is Congress going to do about the cannabis conundrum?


Next, just how deeply will you engage in the cannabis banking world?  Are you only going to open deposit accounts?  What about lending?  It is one thing to bank a cannabis deposit account, but risks compound if you decide to extend credit to a cannabis company.  What if they get shut down by the State?  What sort of collateral (another “C”!) are you prepared to repossess?   Weed?  Agricultural land growing weed?  Commercial real estate selling weed?

You must be comprehensive in your considerations!

Join Rebekah as she goes from the big picture, down into all the various detailed aspects you need to know.  She has the real-life experience to share, in a relatable and engaging way.  Bring your questions!   



Compliance staff, BSA / AML staff, risk managers, loan policy makers, operations managers, operations staff, tellers, new account staff, deposit operations, ACH staff, ATM/Debit card staff, robbery and security staff, legal, and audit.  Nearly everyone.  Cannabis banking has a wide reach!


Rebekah Leonard

Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to "make clear, explain, throw light upon", and describes Rebekah's desire to illuminate the complexities of compliance with passion and fun. She's created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource. Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she's covered nearly all of it - customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams. Rebekah has a bachelor's degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.

Course curriculum

  • 1


    • Access Webinar

  • 2


    • Cole Memos

    • CSBS Cannabis Job Aid

    • FDA Regulation of Cannabidiol (CBD) Consumer Products

    • BSA Expectations Regarding Marijuana-Related Businesses

    • FinCEN Guidance Regarding Due Diligence Requirements under the Bank Secrecy Act for Hemp-Related Business Customers

    • K2/Spice

    • Slides

    • Questions and Answers