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#2247151 - 01/04/21 10:00 PM Poll: CTRs, DOEPs, and CBD
Goldrose Offline
Member
Joined: Sep 2018
Posts: 66
Are you allowing current CTR exempt customers to remain exempt if they sell the CBD products you see at most grocery/convenience/tobacco stores? (From hemp, less than .3% THC etc..)
CTRs, DOEPs, and CBD
single choice ( Total Votes:)
Yes - 0 (0%)
No - 0 (0%)
Undecided - 0 (0%)
Voting on this poll ends: 06/04/21 09:59 PM

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#2247434 - 01/11/21 01:29 PM Re: Poll: CTRs, DOEPs, and CBD Goldrose
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
First - polls no longer work in the threads.

Second, if they not are doing anything illegal, why would you not?
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#2247575 - 01/12/21 10:19 PM Re: Poll: CTRs, DOEPs, and CBD Goldrose
StacyLitkeGCV Offline
New Poster
Joined: Nov 2020
Posts: 14
If it is hemp based, run of the mill CBD, yes. Hemp is legal, as you've defined it in your question, at the Federal level, so if it's a grocery/convenience store that just happens to have CBD on their shelves, which represents a small portion of their revenue there's really not much to worry about. Treat them as you would any other grocery/convenience store.

If on the other hand, the CBD is marijuana derived, sold by a licensed CRB, then they cannot be exempt.

From FinCEN: "A business engaged in marijuana-related activity may not be treated as a non-listed business under 31 C.F.R. § 1020.315(e)(8), and therefore, is not eligible for consideration for an exemption with respect to a bank’s CTR obligations under 31 C.F.R. § 1020.315(b)(6)."

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