By Danielle Hunt, Kalin Bornemann, Olivia Grabacki, and Jessica Roberts As we previously discussed, financial institutions that offer financial services to the cannabis industry have been operating in a state of uncertainty in the wake of the rescission of the so-called “Cole Memo” earlier this year. Without the comfort of the Cole Memo, those financial… Continue Reading
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Update: DOJ Rescinds the Cole Memo—FinCen Guidance Still in Effect, For Now…
Posted in Marijuana, Regulatory DevelopmentsIn the wake of the shift in federal marijuana enforcement policy, financial institutions have been left to speculate the risk in offering financial services to marijuana-related businesses. While the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued guidance in 2014 that laid out a process for financial institutions to open accounts for marijuana-related businesses,… Continue Reading
DOJ Rescinds the Cole Memo—What It Means for Your Financial Institution
Posted in Marijuana, Regulatory DevelopmentsReiterating that Congress considers marijuana to be a “dangerous drug” and marijuana activity to be a “serious crime,” Attorney General Jeff Sessions today issued a memo to all U.S. attorneys rescinding various memoranda related to enforcement of federal marijuana laws issued during the Obama administration. Included in the rescinded memos was the prominent “Cole Memo,” which discouraged… Continue Reading
The Tension Between Financial Institutions and Recreational Marijuana Businesses
Posted in Banking, MarijuanaTo date, eight states and the District of Columbia have legalized recreational marijuana. As you might expect, there are countless key players and businesses involved in the marijuana supply chain, including producers, processors, transporters, retailers, and in some jurisdictions, distributors. In Washington State alone, total sales since the state’s legalization of recreational marijuana have exceeded… Continue Reading