Buzzkill: The AML Implications of Banking Marijuana-Related Businesses
Author: Beth Moskow-Schnoll.; Shawn F. Summers.
Source: Volume 36, Number 09, September 2020 , pp.109-116(8)
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Abstract:
Despite FinCEN’s onerous requirements and the risks involved, in recent years a growing number of financial institutions have been willing to do business with MRBs. The authors discuss the unique legal and compliance risks associated with providing financial services to the marijuana industry and recommend specific controls to mitigate the identified risks.Keywords: Providing Financial Services to Marijuana Related Businesses (MRB); Controlled Substances Act (“CSA”); “Cole Memo”
Affiliations:
1: Ballard Spahr, LLP; 2: Ballard Spah, LLP.