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US – AML Guidance Issued For Banks Seeking To Service Marijuana-Related Businesses

The new FinCEN guidance issued for banks seeking to service marijuana-related businesses clarifies how financial institutions can provide services to marijuana-related businesses consistent with their BSA obligations. Pursuant to the FinCEN guidance, before deciding whether to open, close, or refuse any particular account or customer relationship, the bank should conduct “thorough” risk-based due diligence that includes a variety of tasks including, among other things:Verifying the registration status of the business and other state licensing information and reviewing documentation underlying the license or registration application by the business; Developing an understanding of the normal and expected activity for the business including types of products sold and services offered; Ongoing monitoring of publicly available sources for adverse information about the business and related parties; and Ongoing monitoring for suspicious activity.

According to the new FinCEN guidance, despite legalization of marijuana activities in many states, financial institutions remain obligated to file a suspicious activity report (“SAR”) if there is a financial transaction involving suspected marijuana sales because such transactions remain illegal under federal law.

Despite this latest guidance by the Department and FinCEN, significant risks abound for banks considering doing business with the variety of marijuana businesses that have seemingly formed overnight. Several major financial institutions have already indicated reluctance to venture into this area due to the legal and regulatory uncertainties involved. Banks willing to take on this risk must be prepared to implement due diligence and monitoring programs that are even more rigorous than usual, and meticulously document all due diligence steps and conclusions. This is the only way that banks can attempt to avoid liability when the federal government inquires about particular marijuana-related customers or transactions. Given the likely lack of experience within a bank with norms of the marijuana trade or the myriad state licensing requirements, it is essential that banks proceed cautiously and consult with experienced counsel or external experts before developing policies and procedures to evaluate marijuana businesses.

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