We’re back with part 2 of our mini series about cannabis banking laws, the Cole memo, and the FinCEN guidance.
We’re going to discuss FinCEN filings in detail today, and offer up our opinions about what financial institutions and state legal cannabis companies might do to gain solid ground with deposit banking accounts, transaction processing and more.
In the previous article we discussed the Cole memo, FinCEN reporting procedures and banking in general for the state legal cannabis industry.
We’ve taken a big interest in the state legal marijuana business over the past year and a half, and we believe that as an industry, it should be one that has a framework and structure to safely allow for qualifying companies to do business if they are working in states (or provinces in Canada) that allow them to do so.
In part 1, we talked about the origins of the Cole memo – actually we talked about all 3 Cole memos, the Ogden memo, the introduction of the Rorhabacher-Farr (now Rorhabacher-Blumenauer) amendment, and touched on some of the members of Congress like Rand Paul, Cory Booker and Patrick Leahy who are also supporting the legislation.
We also talked about AG Sessions and his crusade to stamp out cannabis in America, the return of civil asset forfeiture and more. That episode is titled The Cole Memo and FinCEN Reporting Part 1, if you want to check out the archives after this show is finished.
We find that there are two states who are essentially leading the way in the financial sector of the industry. Those two states are Washington and Colorado. This is not to take away from other states (and we all certainly appreciate Earl Blumenauer from Oregon for stepping up to take the lead on the Rorhabacher amendment since Dana Rorhabacher has stated he won’t run again), and we expect that California’s Cannabis Banking Working Group will have some good ideas when they publish a report.