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Investment Management Update – Exit Strategies
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
Despite the proliferation of state laws that legalize the cultivation and sale of marijuana, federal law has remained an obstacle to access to the U.S. financial system for marijuana sellers and producers. With penalties...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
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
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, in consultation with state banking regulators, clarified the legal status of hemp growth and production under the Bank Secrecy Act (BSA) for banks providing financial services to...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
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