DOJ and Marijuana Due Diligence for Banks



The foundation for the DOJ guidance for financial institutions related to banking Marijuana Related Businesses can be found it the Cole memo. Many people have recently contacted me asking for these Priority bullet points from my recent presentation at the spring ACAMS conference. Below please find these points: Eight Priorities

1.Preventing the distribution of marijuana to minors

2.Preventing revenue from the sale of marijuana from going to criminal enterprises, gangs and cartels

3.Preventing the diversion of marijuana from states where it is legal under state law in some form to other states

4.Preventing state authorized marijuana activity from being used as a cover or pretext for the trafficking of other illegal drugs or other illegal activity

5.Preventing violence and the use of firearms in the cultivation and distribution of marijuana

6.Preventing drugged driving and the exacerbation of other adverse public health consequences associated with marijuana use

7.Preventing the growing of marijuana on public lands and the attendant public safety and environmental dangers posed by marijuana production on public lands

8.Preventing marijuana possession or use on federal property

In the near future I will be publishing FinCEN guidance on marijuana commerce. NominoData offers a data file that contains the licensing information about MRBs that have been approved by the 23 “legalized” states. For more information please contact