Anyone out there have any persons/consumers that are investing their own legit assets into entities that are marijuana facilities/farms/retail stores?
https://www.businesswire.com/news/h...ion-Series-B-Preferred-Private-Placement

What do you do with those relationships? Exit? Monitor? Slap wrist? It seems to me like feel free to invest in whatever you want to, but if the investment is a federally-illicit operation then isn't any investment proceeds/profits back to the investor part of the money laundering process?

if the investment is a federally-illicit operation

Not sure I would call that an investment. An actual investor in a legal company though - what would be the difference between that and buying GM stock? And how would you actually know?

Isn't it an investment? It's basically private equity/venture capital. I certainly see your point, I do. Here in CA, these marijuana "corporations" and holding companies are popping up everywhere, and they're doing public investment offerings just like the one in that link I pasted. Sure they're not publicly-traded like GM, but since marijuana is legal by the state but not Fed, would anyone do anything with the consumer relationship if, say, a consumer wired $120000 to that holding entity? The initial investment funds are legit customer savings. Where I'm coming from is this -- I don't care what you invest your money in to make money, but what do we do with the relationship once our customers start getting "investment income" from the holding entity, with us knowing exactly what that holding entity is and where its business is being derived?

Long ago, while considering onboarding a client that had invested in a large MRB and would receive periodic disbursements, I asked FinCEN about SAR implications. They referred me to the DOJ. I eventually got on the phone with a financial crime investigator with the FBI, explained the situation and his was response was, "Well, that sounds mostly legal."

What you do with customers like this is a risk decision, but I get the impression law enforcement has enough to deal with that they don't care about people investing in, owning, managing, working for or buying from state-compliant MRBs.

@ColoradoAML, and that's exactly where I am right now, in fact, is the SAR implication. Would those periodic disbursements be elemental to money laundering considering the clear and obvious source of funds. What would these be called -- capital gains? Passive income? Investment distributions?

I would say that it is a risk based decision.

Also a question would be; is the bank charging sufficient fees to cover the additional monitoring.

I fail to see how dividends paid by a legitimate company to it's investors equates to money laundering. These sorts of offerings have to be vetted by the Security Division in the State in which they operate and/or the SEC.

The "legitimate company" is a cannabis retailer and cultivation operating ten dispensaries in CA and a 30,000 sq. ft. premium indoor cultivation and distribution facility, as well as an exclusive manufacturing partnership with a top concentrate brand.
Is that a legitimate company in the eyes of the feds? Would an investor not be receiving "illicit" funds from such a company?

Then file your SARs and move on until the SAFE Banking Act passes Congress.

Agree with you all. Personally, this nonsense should have been legal decades ago, and I hate nothing more than spending any time or energy or a bank's compliance budget investigating anything having to do with it.
But I just work here

I can't wait for the day it's legalized and the system gets bombarded with cash reserves. Some of are in for a serious roller coaster.