With the legal grey area growing bigger every day between CBD, hemp, and marijuana, you need to establish and document clear guidelines for your institution. It is imperative to identify gaps or potential areas of improvements in your BSA/AML policies and procedures related to cannabis and marijuana related businesses and their known associates.
Every financial institution needs
to make a conscious decision whether or not
they are going to bank CRBs or MRBs.
MRB/CRB Policy and Procedure Review
Due to the ever-changing legal landscape surrounding the use of cannabis and marijuana for recreational, medicinal, or industrial purposes, all financial institutions under FinCEN’s purview need to establish policies and procedures for or against the servicing of cannabis-related businesses (CRB) or marijuana-related businesses (MRB).
De-Risk and Maximize Opportunity
This advisory services package ensures that the proper mitigating protocols are in place to provide services to CRBs and MRBs in a safe and effective manner. For financial institutions that have not created dedicated policies and procedures for these entities, our consultants can free up capacity among your leadership while providing insight into how other institutions handle CRB questions and policies.
This engagement includes:
- Internal stakeholder interviews that are responsible for compliance functions
- Conduct a Risk Assessment
- Audit BSA/AML program
- Create a comprehensive draft revision of their policies and procedures along with the associated supporting documentation
Key Indicators For Our Service
- Institutions that desire to de-risk Marijuana or Cannabis Related Businesses
- Institutions that would like to begin banking Marijuana or Cannabis Related Businesses
- Institutions effected by federally or state regulatory landscape changes
- Institutions with audit/exam findings or a formal enforcement action