Cannabis laws are changing at the Wisconsin borders – Are you prepared?
Prepare for changes with usGet Prepared for the Cannabis Industry
Crossing State Lines
While cannabis remains illegal in Wisconsin, every state bordering it has legalized some form of it, either medicinal or recreational. While you might not think you're banking the cannabis industry, you need a plan and the people power to ensure it. Are you ready?
Talk to a specialistAre you prepared as your neighbors change state laws?
Yes, can you help me? NO, TELL ME HOW TO STAY COMPLIANT
Chose to Bank CRBs
- Customer due diligence (CDD) is key; Know your customer, including beneficial owners, and the full scope of their business(es).
- Ongoing monitoring and enhanced due diligence (EDD) is critical to ensuring all transactions are legitimate. Balance anticipated activity (particularly cash) with actual activity.
- Go for that fee income! Use account analysis as well as a monthly fee for the heightened risk and monitoring costs you will incur.
If you want to Avoid Banking CRBs
- Update your BSA/AML policy to include that your financial institution will not “knowingly” provide services to these customers to exit the relationship if discovered without breaking policy.
- Perform CDD. Ask if the customer is involved in any type of CRB. Put the responsibility on the customer to be honest.
- Use ongoing suspicious activity monitoring for cash volumes and other activity that doesn’t fit the customer’s line of business.
Cannabis Law in Wisconsin
USDA-Approved Hemp Plan
Wisconsin will continue to operate under the 2014 Farm Bill so producers with active contracts may continue completing practices as scheduled.
2014 Farm Bill
Medical Marijuana
Two bills were introduced in 2019 to legalize medicinal marijuana in Wisconsin. The bills include the creation of a state-approved licensing system for growers.
Push for medical marijuana
Neighboring States
Every neighboring state around Wisconsin has legalized some form of cannabis use. With state laws changing at a rapid pace, it's important to stay in the know of other state laws.
Cannabis Laws by the StateSolutions and services to help you clear the smoke.
Solutions
CRB Watchlist Scanning
Experts expect there to be almost 300 cannabis stores in operation in Illinois by 2022. Could any of those beneficial owners also be doing business with your institution? Do you really know your customers/members as well as you think? Our CRB watchlist scanning, part of BAM+ Scan, allows you to use the power of NominoData to scan against state-licensed cannabis dispensaries, ensuring you truly know who you're banking.
CRB Scenarios
With BAM+ CRB Scenarios, your transactions will be scanned weekly against four different scenarios intended to alert you to potentially suspicious activity resulting from unidentified CRBs/MRBs. It will work both as you onboard new relationships and monitor existing ones to avoid any unpleasant surprises down the road.
Advisory Services
CRB Policy and Procedure Review
Whether your institution has decided to service, or not service, CRBs/MRBs, you need to update your policies and procedures to reflect that decision. How are you actively monitoring to ensure you don't unknowingly have a CRB hidden in your customer base? Our Advisory Services team can help make sure you stay in compliance.
SUSPICIOUS ACTIVITY MONITORING
No matter whether you decide to bank or avoid CRBs/MRBs, there is an increased, and often unexpected, amount of diligence and monitoring your BSA department is tasked with. Our Advisory Services team can help act as an extension of your BSA department for a long-term assignment or short-term help so you don't skip a beat.
Marijuana Related Businesses (MRBs) or Cannabis Related Businesses (CRBs) continue to pose heightened risks for financial institutions.
While cannabis remains fully illegal in Wisconsin and at the federal level, laws are changing at the border. What if the laws in Wisconsin change? Is your financial institution ready to monitor against these businesses or provide banking services to them?
While cannabis remains illegal in Wisconsin, you need to learn how to take measure to avoid MRBs/CRBs and be prepared should the laws change and you want to bank these businesses.
Join us for this free webinar to hear from a panel of current BSA executives that are successfully providing services to these businesses or that are successfully avoiding this risk.
Banking MRBs/CRMs: Do These Businesses Fit into Your Risk Profile?
Register for webinar
Avoiding CRBs/MRBs: Too Risky for Us!
Register for webinar
Wisconsin CRB Resources
