Lending Issues in the Cannabis Industry
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Gain a better understanding of banking issues presented by the conflict between the legalized use of marijuana in various states and its treatment as a controlled substance under federal law.This topic will provide a thorough review of the tension between federal and state cannabis regulations as they impact lenders in the industry. The panel will take a deep dive into cannabis specific suspicious activity reports, due diligence requirements, and enforcement issues.
AuthorsOren Bitan, Buchalter Gregg Williams, Trident Pacific Real Estate Group, Inc.
Legalization of Cannabis at the State and Federal Level-Current Status
• Controlled Substances Act
• FIN-2014-G001 and the Cole Memo
• DOJ vs. Treasury Pronouncements
Doing Business With MRBs
• Reporting Requirements Under FIN-2014-G001-SARs
• Compliance With AML and KYC Requirements and the Bank Secrecy Act
• May Be Limited to State Level Remedies
• Issues in Bankruptcy: Federal Jurisdiction