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SAR for Municipalities (Medical Marijuana)

We currently bank municipalities/public funds who are considering allowing medical marijuana business in their community. Sounds like it will cost about $5,000 per license upwards of 25-50 applications allowed. Do we need to report the activity in a SAR that the municipality is accepting applications?

by Ken Golliher: While there would be some logic to that, no. The municipalities that benefit from fees, the state and federal governments that benefit from tax revenues are not directly involved in the cultivation or sale of a controlled substance.


by Richard Insley:

Forget SARs for a moment--maybe the best way to look at this is from the forfeiture perspective. If the cultivation and distribution of marijuana violates federal law, then there's a risk that the feds will consider all profits derived from the illegal activity to be forfeitable. That could include the amounts that operators will pay to the locality for licenses. In forfeiture cases, the money is accused of the crime and then the money is "arrested" and marched off to the U.S. Treasury. If the "criminal" money happens to be on deposit at your bank, then you will be squarely in the middle of this political battle. The lowest risk solution to this dilemma would be to say "thanks, but no thanks" to the municipal treasurer and invite him/her to place the marijuana license proceeds in another institution.

First published on 04/01/2018

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