MRB COMPLIANCE

Banking Marihuana Related Businesses (MRBs)- Data Tools to comply from NominoData

The legalization of Marihuana commerce in an ever-increasing number of States in the United States has resulted in a compliance challenge for financial institutions. Regardless of whether or not an FI chooses to bank a Marihuana Related Business (MRB) or if the FI is situated in a “legalized” state, the bottom line is that all FIs are affected by individuals and entities that are connected with MRBs. Knowing the source of funds from all customers is critical to complying.

Meeting the Challenge

The Department of Justice and the parallel banking regulatory agencies remain committed to strict oversight and enforcement of rules related to funds sourced from legitimate marihuana commerce. This position is directed in the DOJ Cole memorandum and in the 2016 the federal government reaffirmation of Marihuana as a schedule 1 substance. While some U.S. states have “legalized” commerce on various lawful levels, all Marihuana commerce remains unlawful by Federal statute. Hence, FIs must have access to state-by-state data the identifies the legitimate marihuana businesses and their beneficial owners. The data enables FIs to comply with many of the KYC and EDD requirements mandated by Federal and State regulators.mmj-state-map

Data Solution from NominoData

NominoData has developed a data file that identifies legitimate MRBs and their Beneficial Owners in all the disparate “legalized” states. The data file provides up to date information about the businesses and their owners. While each state has different identifying data, generally, the data file has core information needed to conduct primary due diligence and enhanced due diligence of the MRBs. The data is delivered in an easy to integrate format that can be joined with any KYC, transaction monitoring or case Management solution.