As states move forward in both marijuana and hemp, the federal law lags behind in the area of marijuana.  Hemp on the other hand, has been on a journey from the Farm Bill 2018 to the USDA regulations issued at the end of 2019.  Where are we now?  What is FinCEN’s position on hemp and marijuana?  During this program we will discuss, how to check your state statutes, understand where we are now both federally and on the state level with hemp and marijuana.  As the federal government makes way for a new brand of hemp customers, we have to make decisions about banking hemp and what our policy and procedures would look like.  FinCEN has BSA expectations but the good news is that these don’t include filing SARs on hemp customers and related businesses.  This is a 2022 update on hemp and marijuana and may help you shape your decisions about how to move forward as our states and government authorities set the parameters for banking this new industry.

Topics include:

• Understanding the current USDA regulations on Hemp
• Learn how your state law can impact the decision to bank hemp customers
• What is FinCEN’s position on hemp? On marijuana?
• What would be the BSA considerations and risk to our financial institution 
• Writing your hemp and marijuana policy
• Build your questionnaire, risk assessment, CIP, Beneficial Ownership Procedures 
• Monitoring and measuring risk