CannaBanking 1

CannaBanking:

Cultivating a Culture of Compliance

Through Strategic Alliance

Sherri Scott

CannaBanking 2

CannaBanking: Cultivating a Culture of Compliance Through Strategic Alliance

Executive Summary

The fastest growing industry in the country is also the largest underbanked population; the two ingredients combined are a recipe for disaster. According to The Huffington Post, legal marijuana is the fastest-growing industry in the United States (Ferner, 2015). Due to our existing state of affairs, De-Risking has evolved into financial exclusion. Roughly 60 percent of marijuana related and ancillary businesses remain unbanked (Olson, 2015). Consider the view point of your nemesis; if I were a drug lord running an illegal marijuana operation and wanted to hedge my risk, I’d position myself to profit from the legalized business. The potential for criminal enterprises to work themselves into the infrastructure becomes increasingly realistic if the legal cannabis industry continues to remain widely underbanked. Lack of communication amongst a state’s marijuana regulatory body, the federal bank or credit union regulator, and federal agents remains a major obstacle. Failure to implement viable long-term solutions with strict controls in this evolving industry will impede the ability to effectively detect crime and hinder future investigations. If you think marijuana banking doesn’t apply to your financial institution because marijuana related business accounts are not accepted, guess again. Although your financial institution may not currently provide banking services to cannabis dispensaries and cultivation centers, you may not realize you are banking customers who purchase the product, employees who work for the facilities, and countless vendors. If you ever thought of providing legal banking services to a cannabis industry company or you just want to decrease your risk of being abused by one, you need to prepare yourself. Current issues demand a deep dive approach. Taking the time to build a strong strategic alliance now will help guide policy decisions and provide valuable financial intelligence to assist law enforcement. The War on Drugs is nowhere near an end and together we have the ability to build our arsenal. The secret weapon is cooperation.

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Cannabis Sales Soar Sky High

As of June 2016 marijuana has been legalized for medical use in 25 states and the District of Columbia (25 Legal, 2016). With more states seeking legalized marijuana programs and patient awareness decreasing societal stigmas, sales are estimated to increase exponentially over the next decade. The Huffington Post published an article based on a study conducted by The ArcView Group. Results of the study found a 74 percent increase in legal cannabis transactions rising from $1.5 billion in 2013 to $2.7 billion in 2014 (Ferner, 2015). With more states preparing to jump on the band wagon, The ArcView Group estimates that the state run legal cannabis programs will exceed $11 billion dollars by 2019. Marijuana sales in Colorado alone topped $996 million in 2015 (Sky High, 2016). Washington was not far behind with sales of $973 million for fiscal year 2016 (Washington, 2016). With current sales averaging $4.5 million per day, the state of Washington can expect annual sales of roughly $1.6 billion next year. The chart below reveals legal cannabis sales growth in the state of Washington (Maxfield, 2015) and displays the revenue potential for states adopting a similar program.

Cash Without Controls

Danger lies in lax cash controls. In 2012 HSBC was ordered to pay $1.92 billion in fines

subsequent to the laundering of $881 million for Mexican and Colombian cartels (Estevez,

2016). Drug dealers had specially designed cash deposit boxes based on the dimensions of

the teller window for the regular placement of hundreds of thousands of dollars in cash in a

single visit (Rolling Stone, 2012; Taibbi, 2013).

Similar circumstances surround the 2010 settlement for Wachovia, acquired by Wells Fargo,

after laundering billions for international cocaine cartels (Vulliamy, 2011). Recently Wells

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Fargo agreed to a $185 million dollar settlement for two million fake accounts setup by 5,300

former employees that occurred over a five year period (Merle & Marte, 2016)!

In order to effectively fight criminals abusing our financial system, the proper controls must

be in place. Years of undetected and unreported criminal activity is inexcusable. Imminent

threats require immediate action.

The Under-banked

According to a Bloomberg Businessweek article, as of October 2015 roughly 220 banks and credit unions throughout the U.S. accepted legal marijuana business accounts (Kaplan, 2015). That same article addresses the difficulty faced by one Colorado marijuana entrepreneur who has dealt with more than eight banks regarding his legal marijuana business account. Although the number of FIs participating in the taboo is rising, that still left nearly 70 percent of the cannabis cultivation and dispensaries (notated as “Plant-Touching” in the chart below) and businesses that serviced them (“Ancillary”) without banking services as of year-end 2015 (Olson, 2015). Ancillary businesses run the gamut from consultants to armored truck couriers. In some cases, individuals attempting to open legal marijuana business accounts have even had their personal accounts closed by their FIs. Latest figures indicate the number of FIs accepting legal cannabis business accounts rose to 301 by March 2016 (Sacribey, 2016). The fact remains that legitimate business owners are unable to obtain banking services, yet are expected to function under the highest scrutiny in the most regulated industry in the world.

It is difficult enough for the marijuana cultivation centers and dispensaries to compete with

each other. Add on the complexity of operating in a state that only allows medicinal marijuana

with limited qualifying conditions and a low number of eligible customers. Most cultivation

and dispensary owners are not eligible to purchase or try the products they are soliciting if

operating in states where marijuana use is limited for medicinal purposes.

Put yourself in their shoes and imagine that in addition to the pressure of starting a new

business in an evolving new industry. You have done everything by the book and think you

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have your financial affairs in order, and one day wake up to a media announcement that your

FI is backing out of banking the legal marijuana industry and the other FIs are already at their

limit for cannabis accounts. What would you do? In many cases, they use MSBs or other

accounts just to pay bills.

Stay informed even if you do not bank the legal marijuana industry

Roughly 95 percent of FDIC insured institutions refuse to provide banking services to legal

cannabis cultivation centers and dispensaries. Although the marijuana related accounts are

being denied, there is a high probability that some FIs have been abused by those concealing

information. From the use of personal accounts at the nation’s top five largest financial

institutions (particularly for large marijuana corporations operating in multiple states) to the

credit union down the street in rural America, marijuana industry professionals have admitted

to using personal and other business accounts out of desperation.

State officials who oversee the licensing of marijuana cultivation centers and dispensaries or

the state program in totality need to be designated as marijuana Politically Exposed Persons

(PEPs). They have a higher probability of being involved in corruption due to the high level of

politics and potential for enormous wealth. The marijuana industry is controlled by the

government and the permits are limited. The decision to award those permits will determine

who becomes a future millionaire.

There needs to be increased monitoring of municipal accounts, alderman, and village

presidents for unusual activity subsequent to the opening of a legal cannabis entity in the

area. Several municipalities are interested in charging cannabis dispensaries a percentage of

revenues on top of the existing costs. Smaller municipalities tend to have less dual controls in

place compared to a larger metropolitan area. A portion of those funds ending up in the

private account of a city or state official is not outside the realm of possibility. Rita Crundwell

holds the record for the largest municipal embezzlement case in American History (Wikipedia,

2016). She managed to swindle $53.5 million dollars from the city of Dixon, Illinois where she

served as Comptroller and Treasurer for 29 years.

Other considerations should be made to monitor the personal accounts of cannabis

cultivation and dispensary employees. Cases have been reported of employees being asked

to make change or use personal accounts until the company can open a bank account. The

same goes for personal accounts of investors and owners of legal marijuana facilities. Several

lawyers are investors and owners and may use their law firm accounts when a bank account

cannot be obtained. Holding companies may own the real estate where marijuana is being

produced and sold. ATM providers are miscoding their customers to conceal the true purpose

of the transaction. Crosscheck your customers ATM locations with addresses of known

cannabis dispensaries. If you service MSBs, extra time should be allotted to review increased

activity resulting from unbanked legal marijuana activity in that area.

Ensure systems are setup to monitor clinic and physician accounts receiving payments from

marijuana dispensaries, cultivation centers or unusual cash deposits. This activity could be the

result of illegal kickbacks or indicative of criminal activity. Several convictions have revolved

around physicians writing unnecessary prescriptions. Dr. Sujdak and his former nurse

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admitted to providing medical marijuana certifications for over 7,000 patients in one year,

most without an in-person evaluation. They were caught after an under-cover cop purchased

a recommendation pre-signed by the doctor for $100 at a Denver medical marijuana show

called Hempcon (CBS Denver, 2014).

Caregivers are able to purchase legal cannabis for their patients. You may observe unusual

cash deposits if a caregiver is abusing the privilege of buying the product for a patient and

pocketing a portion of the drug for profit. Aside from theft, it may also be indicative of elder

abuse. In an interview with a local home-based, care-giving agency, the owner did not want

his caregivers to purchase or provide marijuana to clients. He fears the temptation for his

employees to steal is too much.

If you have any suspicion regarding a customer, notate discussions with senior management

and take precautions. It is better for you to identify deceit from a customer if you were

unknowingly banking a legal marijuana operation, and take immediate action instead of

having it pointed out to you during an audit or examination.

CannaBanking: To Bank or not to Bank?

Regardless of the size and complexity of the FI, the regulatory standards remain the same. If the institution does not have the resources to implement effective controls to meet regulatory guidance, then they should not take on the responsibility of banking the legalized marijuana industry. The FI should contact its local regulatory authorities and schedule a meeting to discuss the FIs interest in banking the industry. Prior to providing banking services in the legal marijuana industry a multitude of well documented steps must be taken. Compliance and BSA Officers, senior management, and the Board are expected to be knowledgeable of with the Cole Memorandum (Cole, 2013) as well as the Treasury Department guidance issued by the Financial Crimes Enforcement Network (FinCEN, 2014 Feb). Familiarize yourself with the state code, laws, or proposed laws regarding the legal marijuana program for the states you are banking. Policies, policy limits, and procedures need to be approved by the board, and thoroughly documented prior to accepting marijuana deposits. Is the Board informed? What type of information and how frequent? Are they aware that they can be personally held liable for FinCEN and BSA violations? Unless it can be proven that an individual committed an egregious act, the fines are typically assessed to the institution as in the “Kids for Cash” scheme (Rubenfeld, 2015). These are questions that need to be answered prior to commencing involvement in the industry. A Board member should be able to speak intelligently on the FIs plan for the program, the risks involved and what the FI is doing to mitigate those risks. The Board should have a rough idea of the concentration of the marijuana account activity in relation to policy limits. The Board ought to be able to refer to materials provided at the meeting, and discussions need to be notated in the Board minutes.

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Reports should be provided monthly, quarterly, or as frequent as deemed necessary. The content of those reports should include:

The number of SARs and further explanation if warranted (such as criminal activity).

Currency Transaction Reports (CTRs) filed with FinCEN related to cannabis business accounts.

The reports should also include the percentage of marijuana accounts to total deposits and capital.

A thorough marijuana package will include the stratification of business demand deposit accounts from the certificates of deposits and escrow accounts.

Reports should also include any loans, lines of credit, and letters of credit related to marijuana business customers.

Ancillary and other accounts that have a relation to the marijuana accounts must also be identified and tracked.

You must be able to come up with a figure for expected/predicted activity for the cannabis business account when you open the account. How to establish a base line when one does not exist? It is exciting to be involved in banking a new industry; unfortunately, one of the downsides is that there is not a good way to determine a baseline. The rules vary from state to state, and the market conditions are dependent upon unique attributes. This does not give the FI an excuse to not have a prediction for expected activity. Several marijuana cultivation and dispensary business owners hired consultants from states with existing marijuana programs, to assist in creating pro-forma financial statements. The pro-forma statements provided in a business plan collected at account opening are a good starting point for determining sales for that business. The difference between the patron count in that state, the market area for that location (i.e. urban vs. rural), and the difference in taxes and other expenses, such as the cost of banking, are factors to consider. The BSA Officer should be seasoned and have had thorough training and credentials to implement and oversee a high-risk program. The procedures from account opening to Suspicious Activity Report (SAR) filings need to be documented and well thought out. In addition, the financial institution needs to have an adequate number of well trained staff to ensure dual controls and effectively execute the program. Dual control will aide in reducing the number of exceptions to internal policy, procedures, and regulatory requirements. Make sure that someone is double checking the CTR, and SAR filings are being performed adequately and in a timely fashion.

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Personal liability as the BSA Officer:

Do you really have the authority?

Were you hired on after the bank was already engaged in taking deposits?

Were you involved in Board discussions pertaining to the program?

Do you feel that you have resources necessary to oversee this program?

It is imperative that you document your stance on the program because your reputation is ultimately at risk. As BSA Officer, you can be held personally liable for your actions, or lack thereof. In 2014 FinCEN assessed a $1 million civil money penalty to the former Chief Compliance Officer for MoneyGram International Inc. (FinCEN, 2014 Dec). Make sure to thoroughly document your actions and protect yourself. FIs need to make sure that the team assigned to oversee the legal cannabis program has adequate resources -- from human capital to monitoring capabilities. The internal tracking system must be suitable and the staff properly trained on how to set new parameters and utilize the software. New CDD/EDD procedures issued by FinCEN require ownership greater than or equal to 25 percent to be identified (Federal, 2016). Although FIs have until May 11, 2018 to implement the final rule, it would be prudent to perform this exercise now. Not only will you be meeting future criteria, but you will be identifying key players who may be relevant or currently involved in criminal activity.

Regulatory and FI Solution

The regional offices of the federal bank and credit union regulatory agencies must be

responsible for determining which FIs are eligible and grant permission prior to the

institution offering services in the legalized marijuana industry.

Banks and credit unions should undergo a similar process an entity undergoes to obtain a

license to manufacture and solicit legal marijuana. The decision to embark the cannabis cash

cow, and request approval to bank the legal cannabis industry will lie in the hands of the FI.

After the application process, the determination of the eligibility of the FI applying for

permission to bank the industry needs to be reviewed and a decision made at a regional

banking level. When a state utilizes its resources through a strategic alliance and engages the

federal banking authorities, the timeline can be in synch so that these events are happening

simultaneously. The solution below represents a system that would allow banking services to

be made available to legal cannabis licensees immediately or shortly after they are awarded

approval by the state in which they will be operating.

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The decision should be made by the federal agency, as opposed to the state, to decrease

potential conflict of interest and corruption. The state regulatory agencies already have the

power to decide which facilities in the state are eligible to produce and sell the legal

marijuana. For the state banking authority to determine which FIs are to be rewarded

eligibility to service that industry is simply too much power in one entity. Delegating that task

to a federal regulatory agency helps instill a fair decision making process, and provides dual

controls by separating the state from the decision making process.

Federal bank and credit union regulators are prepared to examine the FIs that engage in

banking legal marijuana. Conflict will be introduced if the state bank authorities determine

the outcome. Each state engaged in a legal cannabis program implements a unique approach

such as Illinois denying FIs site visitations. How can a financial institution conduct a site visit

as per industry standards for Enhanced Due Diligence (EDD) when state agencies explicitly

prohibit the FI from entering the cannabis facilities it services? This is a real problem. Allowing

the FIs to conduct independent reviews will allow them to meet EDD requirements and

simultaneously strengthen oversight of the state approved operation. It is imperative to take

the local regulatory perspective into consideration; however, the decision must ultimately lie

in the hands of the federal authority as the standards vary from state to state.

The decision as to whether or not an FI is approved to compete in the legal cannabis field

needs to be determined at the regional level office, by a designated group of experts. Too

frequently, local field offices and the examination standards amongst them vary by location.

A handful of regional offices, compared to hundreds of field offices, increase the likelihood of

equality amongst FIs seeking approval to engage in the legal marijuana trade.

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It is necessary that all FIs uphold the same standard, regardless of the variation amongst state

programs. The best approach is to uphold the most stringent level of expectations, in order

to set the bar high and meet requirements, regardless of whether a particular state is more

strict or lenient in its local mandate. The approval process should consist of a review of the

historical and current standing of the institution, including examination ratings, negative

press, pending lawsuits, and so on.

Staff at smaller to midsize institutions wear several hats, and have expressed being

overwhelmed with existing tasks without the burden of a new field that requires no room for

error. Part of the determination process must include confidential interviews with the

Compliance/BSA Officer and staff. It is imperative that interviews are conducted in a neutral

location, such as a local field office or the regional office, allowing the interviewee to speak

freely. This will play a lead role in overseeing the account activity, and customer due diligence

process of marijuana related businesses. Conversing solely with the Board and senior

management is a disservice to the process.

Once a determination is made by the regional office, the FI will receive a letter indicating it is

one of the approved FIs to provide legalized marijuana banking services. This letter can be

given to its customers upon request, the same way the institutions request the award letter

from the state licensing agency. That institution will also be added to the list the regional

office provides to state marijuana licensing agencies within its jurisdiction. The legal

marijuana licensing agencies will update the lists for the cannabis cultivation centers and

dispensaries, as an option for a banking solution.

Not only will this allow the regional offices a firsthand opportunity to vet the FI, it will assist

in helping local field offices determine the staffing needs in advance rather than finding out

after the fact. It will also allow policy limits to be set prior to an FI banking the robust industry,

and may even enable the FIs in the state to pre-plan and set geographic boundary limits if it

knows a neighboring FI was also approved to operate in a specific area.

An optimum number of FIs ought to be chosen, and a list of eligible places for the cannabis

companies to obtain business accounts and conduct financial services provided to the state

cannabis authority. The reason behind having a pre-approved list of FIs in place, before

awarding legalized marijuana licenses, is that the state agency should require the cultivation

centers and dispensaries to maintain a bank account and conduct financial transactions

through one business account per location. This will force transparency and create a paper

trail for audit, and decrease the off-the-record transactions. It is recommended that any

unapproved FI knowingly conducting bank services for the legal marijuana industry face

enforcement action and fines.

Cultivators should only be paid by dispensaries via check, cashier’s check, internal transfer, or

wire (Note: if wires are conducted through a correspondent bank, make sure you have prior

approval). This should be the case even if the cultivation center and dispensary are owned by

the same holding company.

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If expenses are combined, the marijuana entity needs to form a separate holding company

and maintain a separate business bank account for that entity. It is necessary to have separate

business accounts for each facility to force transparency. Furthermore, the funds need to be

kept separate, so the FI can properly fill out the usual activity on the continuing SARs for

FinCEN.

Allowing large-scale operations to have one bank account for multiple dispensaries and

cultivation centers will increase the number of related scandals down the road. Forcing the

large operations to break down the financials will make the due diligence for each branch

more reliable. If the marijuana facility insists that the accounts must be kept as one, as noted

earlier, a separate entity should be legally established for administrative purposes, and each

facility should pay a percentage of that overhead based on size, percentage of net income, or

some other variable. Combining multiple facilities allows the entity to keep internal records,

and it will be much more cumbersome for the FI to deconstruct and identify illicit activity!

Require the FIs banking legal marijuana to participate in the information sharing program that allows FIs to share information with each other regarding suspected involvement of money laundering or terrorist financing – Section 314 (b) of the USA PATRIOT Act. If a cannabis dispensary or cultivation center has multiple accounts, and an institution suspects money laundering, this will allow for more rapid communication amongst FIs. There is no need for a cannabis company to maintain more than one bank account per facility; however, if multiple accounts are being used in different financial institutions, this will afford banking allies the ability to trace the movement of those funds amongst multiple accounts.

Legislative/Legal Marijuana Licensing Agency Solution

It must be made clear to state legislators that the laws must be written to give FIs the legal

authority to conduct in-person site visits to both the cultivation centers and dispensaries to

meet EDD requirements, and uphold safe and sound banking practices. The FI has

individuals trained specifically to detect money laundering and suspicious activity. Taking

away the site visit component hinders that determination.

In an ideal world, legislators engage the federal banking authorities prior to finalizing a

marijuana related program. This would allow the federal agency to put out an application

process for FIs to apply and submit documentation required to service the industry. Once the

regional office provides the state with a list of approved FIs, the state could proceed in

awarding legalized cannabis cultivation center and dispensary licenses. A binding condition of

that award is that financial transactions for each facility must be conducted through a single

business account held at a regulatory approved FI. The funds derived from legal cannabis sales

have to be deposited into the business account at the FI.

If the facility operates an ATM or Kiosk, that should be done through a third party, or those funds must remain in a separate bank account, and should operate as two separate entities to ensure the ATMs are not being filled with the funds derived from legal marijuana sales. This will force some transparency and provide a better paper trail to determine whether the proceeds of marijuana sales are ending up in the hands of criminals.

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Elected government officials need to touch base with the local state banking association, state and federal banking regulators, and any banks that may be interested in banking the field. Allow the banks the legal authority to access the facilities regularly to meet their obligations under The Bank Secrecy Act (BSA) to conduct EDD. It is the bank’s responsibility to increase shareholder value and simultaneously uphold safety and soundness obligations. Not allowing the bank access to the facility will further impede the ability of the marijuana dispensary and/or cultivation center to receive banking services.

Chair of the California State Board of Equalization, Fiona Ma, summed up the frustrations

shared by many professionals responsible for determining revenue and collecting state taxes

for the legal marijuana industry. In her blog published by The Huffington Post, Chairwoman

Ma stated, “As the state continues on its path to economic recovery, I am concerned about

the hundreds of millions of dollars that disappear into an underground cannabis economy

that is robbing our schools, public safety and local governments of the full funding they are

entitled to (Ma, 2015).”

Be transparent with the public. The state website should provide information regarding the

dollar amount of sales from dispensaries and cultivation centers. Show taxpayers where those

funds are allocated such as the percentage of the funds towards taxes, overhead,

municipalities, and school drug prevention programs. This is important in states that face

public trust issues derived from a history of political corruption. Collaborate to form a

strategic alliance, strengthen relationships, and avoid industry-wide financial exclusion.

ATM Solution

Prohibit ATMs in legal cannabis dispensaries, until a national bank acknowledges it services

the large ATM processor who has thousands of ATMs in the thousands of cannabis

dispensaries throughout the nation.

If the marijuana dispensary owns or pays for the ATM to be located in a neighboring non-

cannabis related business, make sure the ATM account is replenished with separate funds

linked to a separate business account to avoid re-filling the ATM with marijuana proceeds.

Track the ATM report with business account deposit and withdrawal activity.

I interviewed four national ATM processors, none of whom wanted to be identified. Not one

could provide the contact information for the national bank that was servicing their business

account. Additionally, the interviewees declined to answer when I repeatedly asked how the

marijuana business transactions were identified and what North American Industry

Classification System (NAICS) code the ATM processor is using. The ATM processor must

maintain this information, and provide upon request to the FI holding the business account

for due diligence purposes. The national banks holding these business accounts are

supporting a vendor that has several thousand ATMs in cannabis dispensaries across the

country.

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It is the responsibility of the ATM processor to provide contact information for the FI holding

its business account to verify that the FI is aware that the ATM processor has ATMs located

inside legal marijuana dispensaries. Until that occurs, ATMs should be prohibited in legal

marijuana facilities, and the facility should be fined, have their business account closed,

and/or state marijuana operator license revoked until the situation is resolved.

Law Enforcement Solution

The formation of a powerful Strategic Alliance will allow each entity to maintain its individuality and exponentially maximize its resources to avert and cease the ability for criminal enterprises to profit from the multi-billion dollar legal drug industry. In some states, it may be too late to prevent illegal activity resulting from legal drug sales. The best approach is for each state to have a strong strategic alliance. This solution is flexible and will vary state to state based on the level of activity and potential exposure. If you are in a state that is not participating in a legalized marijuana program, the entities should, at the least, have a list of contacts in other states, or know who to contact locally to get that information. At a minimum, the membership of an effective strategic alliance needs to be comprised of the following individuals: Strategic Alliance Local and Federal Law Enforcement Agencies State and Federal Regulatory Agencies Financial Institutions (FIs) that service the industry State and Federal Sales/Income Tax Agencies Yes, the state authority monitors seed to sale tracking, sight inspections, 24/7 video surveillance, background checks, etc. However, your banker may be able to help with accounts that are separate, yet associated to the business, and may be indicative of criminal behavior based on the expertise of well-trained anti-money laundering specialists employed by the FI. As an example, it may be of interest to your counter-intelligence unit that the wife of a local dispensary owner, who is also listed as an employee of the facility, wires funds from her account to an associate in a foreign country that equates to a percentage of sales. In a lengthy discussion with a state trooper, it was evident that he felt banks didn’t have investigative authority. If you dismiss your local banker as an ally, you are doing yourself a disservice. Pick up the phone, send an e-mail, a letter, or meet with the bank compliance officer or BSA Officer. This will enable the bank to expedite future cases.

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Conclusion

The solutions presented require monitoring unlike any other high-risk industry. There is a

higher risk for drug cartels and criminal organizations to comingle illegal marijuana operations

with the state-run legalized market. There is not one great solution to this epidemic. My work

experience afforded me the opportunity to work with the US District Attorney on a fraud case

and also as an Investigative Specialist for the Federal Bureau of Investigation. As a former

federal bank regulator, investigator, and community banker, I have seen firsthand the need

for stringent oversight.

If your financial institution is going to bank the cannabis industry, it must be done with rigor.

If your financial institution is not going to bank the industry, be aware and informed to stay

abreast on the entities attempting to use your financial institution by concealing their

involvement in the industry. For legislators who work with the state marijuana program,

involve the banking entities in your meetings/discussions when proposing new laws or

changes to existing laws. If you are an investigator, reach out to the individuals overseeing

the marijuana business accounts at the FIs in your state.

After working relentlessly to form a strategic alliance with state legislators, state agencies

delegated oversight of the legal marijuana program, state law enforcement, federal agents,

FIs banking marijuana, and the state banking association to create a national standard, it is

evident that the status quo requires a consistent resolution. What do you do when you

exhaust your resources? Write.

A powerful strategic alliance will conquer current obstacles. The solutions presented provide

a national banking solution for the industry, demand transparency, and limit the opportunity

for criminals to profit from the multi-billion dollar legal marijuana industry. Working together,

we possess the power to prevail over depravity.

“Alone we are smart. Together we are brilliant.”

-Steven Anderson

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