A bit of a twist on the normal question, let's say a bank has knowledge that its customer is a MRB customer or, to take it a step further, a trust is asked to pay medically prescribed prescription costs for medical marijuana products. Does anyone have any thoughts or information regarding either of these two scenarios or how others have handled those? Thanks.

My opinion, A lot of banks bank MRB businesses today. Clearly these are high risk and go through the normal CDD process and reporting structure. As to your second question related to a trust, not sure it is the bank's responsibility to monitor transaction activity in a trust. You are not the trustee.

I should have been more clear. When I was referring to a MRB customer, I meant a consumer customer of the MRB. In the second hypothetical, I should have made clear that this could be a trust where the bank would be the trustee. Sorry, this is the first time these questions have come up.

I've been to many BSA conventions and there are almost no banks that will bank MRB's. Those that do charge around $1500 per month to have an account to cover all the expenses associated with banking that type of business.

So, to be sure we understand the question:

Scenario 1: Bank's customer is a purchaser of state-legal marijuana products.
Scenario 2: Same as scenario 1, except that the bank's customer is a trust, and the bank is the trustee.

Correct in both cases. In the second scenario, the purchaser would be the beneficiary of the trust. The issue to me that changes everything is actual knowledge, at least in the current state of regulation.

In scenario 1, I don't think FinCEN or LE would care (if they care who's buying legal pot, just set up outside the potshop).
In scenario 2, My gut reaction is this is something I wouldn't be comfortable with.