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MRB Compliance

Banking Cannabis Related Businesses (CRB)



The legalization of cannabis 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 Cannabis Related Business (CRB) 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 CRBs. Knowing the source of funds from all customers is critical to complying.


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 cannabis commerce. This position is directed in the DOJ Cole memorandum and in the 2016 the federal government reaffirmation of cannabis as a schedule 1 substance. While some U.S. states have “legalized” commerce on various lawful levels, all cannabis commerce remains unlawful by Federal statute. Hence, FIs must have access to state-by-state data the identifies the legitimate cannabis 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.

Data Solution

NominoData has developed a data file that identifies legitimate CRBs 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 CRBs. The data is delivered in an easy to integrate format that can be joined with any KYC, transaction monitoring or case Management solution.

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NEW Registered Entities Screening Solutions

Nomino Data has partnered with Senzing, Inc. to offer a complete package of screening and linking capabilities integrated with the powerful Nomino Data CRB Compliance marijuana related businesses database that is easily deployable in your environment with simple interfaces to your customer files.

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