Banking Recommended AML, BSA, KYC, EDD, POS, and S2S Compliance Protocols

For licensed entities which dispense, cultivate or manufacture marijuana

  • Verifying with the appropriate state authorities whether the business is duly licensed and registered
  • Verifying with the appropriate state authorities whether the business is currently in good standing and in full compliance with mandated standards, reporting and regulations
  • Reviewing the license application (and related documentation) submitted by the business for obtaining a state license to operate its marijuana-related business
  • Requesting from state licensing and enforcement authorities available information about the business and related parties
  • Developing an understanding of the normal and expected activity for the business, including the types of products being sold and the type of customers to be served (e.g., medical vs. recreational customers)
  • Review of publicly available sources, including law enforcement for adverse information about the business and related parties
  • Review of existing procedures and practices to prevent the following:
  • ✔ The distribution of marijuana to minors

    ✔Revenue from the sale of marijuana from going to criminal enterprises, gangs and cartels

    ✔The diversion of marijuana from their state where it is legal under state law in some form to other states

    ✔State-authorized marijuana activity from being used as a cover or pretext for the trafficking of other illegal drugs or other illegal activity

    ✔Violence and the use of firearms in the cultivation and distribution of marijuana

    ✔Drugged driving and the exacerbation of other adverse public health consequences associated with marijuana use

    ✔The growing of marijuana on public lands and the attendant public safety and environmental dangers posed by marijuana production on public lands

    ✔Marijuana possession or use on federal property

  • Detailed background report on all the enterprise’s principals including:
  • ✔Address history

    ✔SSN trace

    ✔Nationwide Criminal History

    ✔Sex Offender Search

    ✔OFAC/Terrorist search

    ✔Federal Crimes Search

    ✔SSN Fraud Verification

  • Detailed Business Information and Credit Report
  • Comprehensive Physical OnSite Compliance Inspection
  • Detailed Compliance Report reviewing all operational practices specific by state and the type of business
  • Depending upon bank regulator requirements: Real-time, daily, weekly, or monthly Point-of-Sale (POS) monitoring and reporting
  • Compliant Seed-to-Sale Inventory Tracking synchronized with state licensing authority, where applicable
  • Encourage licensed customers to deploy a standardized compliance scoring app based upon 250+ state and business-type-specific regulatory requirements and relevant data points