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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more
The IRS’s Office of Chief Counsel recently published a memorandum providing information for cannabis companies struggling to comply with the completion of Form 8300, which must be filed every time a company receives a cash...more
For financial institutions who engage in marijuana-related banking services, the primary compliance challenge remains the disconnect between federal and state law, as it is still illegal to manufacture, distribute, or...more
Despite the cannabis industry’s explosive growth, many financial institutions have been hesitant to transact with cannabis-related businesses given the ambiguity created by divergent state and federal cannabis laws. The SAFE...more
Live Life Federal Credit Union, a $69 million-asset credit union based in Fraser, Michigan, recently consented to a cease-and-desist order issued by the National Credit Union Administration Board (NCUA). The enforcement...more
On June 29, 2020, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued guidance (the 2020 Guidance) clarifying requirements under the Bank Secrecy Act (BSA) for financial institutions providing...more
The Financial Crimes Enforcement Network (FinCEN) published guidance (Guidance) on customer due diligence requirements under the Bank Secrecy Act (BSA) for hemp-related customers on June 29. ...more
In November 2018, Missouri voters passed Amendment 2, setting in motion state regulated medical marijuana. Over the last month, the Missouri Department of Health & Senior Services (DHSS) began approving license applications...more
FDIC and OCC Propose CRA Modernization Rule with Opt-Out for Small Banks The FDIC and the OCC have jointly proposed amendments to modernize the agencies’ Community Reinvestment Act (“CRA”) regulations, which are intended...more
On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more
On September 25, 2019, the US House of Representatives ("House") passed, by a vote of 321 to 103, the Secure and Fair Enforcement Banking Act ("SAFE Banking Act"), bipartisan legislation designed to secure and regulate...more
On August 20, 2019, the National Credit Union Administration issued a regulatory alert to all federally insured credit unions providing "interim guidance" regarding the service of hemp businesses by credit unions. The alert,...more
We regularly blog about the conflict between state and federal law related to cannabis and the uncertainty regarding how federal criminal and Bank Secrecy Act (“BSA”) law will, or will not, be enforced against financial...more
The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of the Treasury, issued guidance on February 14, 2014 (the “Cannabis Guidance”), to clarify Bank Secrecy Act expectations for financial...more
Can marijuana businesses receive federal copyright protection? Yes. The requirements for registration with the U.S. Copyright Office are that the work is original, creative and fixed in some form of expression. These...more
The 2016 election will be remembered not only for the memorable presidential race but also for what was effectively a national referendum on cannabis. Eight states passed laws allowing its use. Medical marijuana is now...more