FinCEN Releases Bank Secrecy Act Guidance on Marijuana-Related Businesses
On February 14, 2014, the Financial Crimes Enforcement Network (FinCEN) issued guidance on Bank Secrecy Act (BSA) expectations for marijuana-related businesses.
The seven page guidance comes as a result of some states legalizing marijuana activities and the need of related businesses to obtain financial services from financial institutions. FinCEN issued this guidance to make financial services more available for marijuana-related business and still comply with BSA requirements.
The guidance explains how financial institutions can provide services to marijuana-related business and meet the objectives of BSA. Member/customer due diligence of marijuana-related business accounts is a critical component of BSA compliance.
The guidance sets forth several steps financial institutions should take in the due diligence process. In addition, financial institutions are instructed to file “Marijuana Limited”, “Marijuana Priority”, and “Marijuana Termination” suspicious activity reports (SARs) in certain situations.
The guidance is a must-read for financial institutions considering providing services to marijuana-related businesses.
CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.
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