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Top 10 Cs of Cannabis Compliance

Recorded on February 21, 2024

Like it or not, cannabis banking is here to stay. Social stigmas are changing, political winds are shifting, and tax coffers are burgeoning. Financial institutions are taking note, and eyeing entirely new types of profitable banking relationships.

How can banks and credit unions enter this unchartered (and still federally illegal) territory? Can it be done in a way that keeps board members, shareholders, customers, and employees happy? More importantly, can it be done in a way that keeps regulators and examiners happy?! (After all, if they aren’t happy, nobody will be.)

Yes. It is certainly a balancing act – one that must be handled with eyes wide open and with much planning – but it can be done. First, you need to get an idea of what you are even dealing with before you can move into real planning and implementation. Most bankers don’t have a clue about cannabis, and a crash course is critical. These “Top Ten Big Cs” are crucial considerations:

Cannabis: What exactly are we talking about? Marijuana; hemp, CBD? What is the difference, anyway?
Compliance: With what, exactly? Federal, State, Local?
Convictions: Will your Board, management, employees, and customers accept your bank’s involvement in the cannabis industry?
“Cole Memos”: Both of them, and what they mean to you
Cash: In all its smelly (or not?), voluminous, AML-related glory
CTRs and SARs: Special considerations
Customers: You say you don’t bank cannabis customers yet? Sorry to break it to you but: Yes, you do. Right now. And they carry a lot of baggage. Once you offer a cannabis banking program, they will arrive with loads of issues to work through!
Cards: Surprising compliance traps when it comes to debit / ATM cards and cannabis
Cost: Yours and theirs – more than monetary
Controls: From risk assessments to transparency and daily oversight – who does what, when, and how?
(Bonus!) Crystal ball: What is Congress going to do about the cannabis conundrum?

Next, just how deeply will you engage in the cannabis banking world? Are you only going to open deposit accounts? What about lending? It is one thing to bank a cannabis deposit account, but risks compound if you decide to extend credit to a cannabis company. What if they get shut down by the State? What sort of collateral (another “C”!) are you prepared to repossess? Weed? Agricultural land growing weed? Commercial real estate selling weed?

You must be comprehensive in your considerations!

Join Rebekah as she goes from the big picture, down into all the various detailed aspects you need to know. She has the real-life experience to share, in a relatable and engaging way. Bring your questions!


Compliance staff, BSA / AML staff, risk managers, loan policy makers, operations managers, operations staff, tellers, new account staff, deposit operations, ACH staff, ATM/Debit card staff, robbery and security staff, legal, and audit. Nearly everyone. Cannabis banking has a wide reach!