During this program we will give you a copy of all the states marijuana laws and those pending at the legislature. You will receive a business account worksheet and questions that need to be asked about marijuana businesses. It will give two avenues: how to proceed if you do not want to bank marijuana businesses and how to proceed if you do. You will work similar to Money Service Businesses on licensing on state requirements. But here is the question, buying and selling marijuana is still a federal crime. Are you prepared to file SARs on an on-going basis for the duration of the account. The Cole Memorandum and guidance from FinCEN will give direction for the information and the requirements that you will have to meet at the federal level to bank these now legal businesses.
- Controlled Substances Act versus state laws
- Eight key points of the Cole Memorandum
- FinCEN guidance on how to provide services to marijuana related businesses
- FinCEN's factors to consider in your decision to open, close, or refuse any particular account or relationship
- FinCEN's three tiered SAR approach-Marijuana limited, Marijuana Priority and Marijuana Termination SARs
- Red Flags to Distinguish Priority SARs
- Common state law themes and definitions-Marijuana Cultivation Centers, Marijuana Processors, Marijuana Producers, Marijuana Establishments, marijuana Product manufacturing facility, Marijuana Retail Store, Marijuana dispensary, Marijuana Retail Stores and more
- And many more questions you need answers to
WHO SHOULD ATTEND?
Bank Secrecy Officers, BSA Coordinators, CIP Personnel, Security, Compliance New Accounts representatives, Personal Bankers, Member Service Representatives, Branch Operations, Branch Managers and anyone that manages the deposit area.
Opening Accounts for Marijuana Businesses: CIP, CDD
State Law Supplemen
Questions and Answers
RELATED PRODUCT: Marijuana-Related Business Policy Template