Category Archives: FinCEN

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O Canada! What Canada’s Nationwide Legalization of Cannabis Means for American Financial Institutions

Today marks a significant shift in cannabis policy, both domestically and internationally, as Canada becomes the first industrialized nation in the world, and only the second nation overall, to legalize cannabis. This follows the passage of The Cannabis Act in June of this year, which legalized cannabis at all levels of government. With this blessing … Continue Reading

Providing Banking Services to the Legal Marijuana Industry: Mitigating Risks to Maximize Potential Rewards

Since 1996, when California became the first state to legalize marijuana (at the time, for medicinal purposes only), 28 additional states and the District of Columbia have legalized marijuana to some extent. Public support for legalization continues to rise as more and more jurisdictions loosen their marijuana laws, with 64 percent of Americans in favor … Continue Reading

Meltdown of the Iran Nuclear Deal—Sanctions Update

On May 8, 2018, President Donald Trump announced that the United States would no longer participate in the Joint Comprehensive Plan of Action (JCPOA), the international agreement regarding Iran’s nuclear activities and sanctions imposed on Iran that was entered into in July 2015. The Treasury Department’s Office of Foreign Asset Control quickly issued a frequently … Continue Reading

Navigating Through the Hazy Intersection of Financial Services and the Legal Marijuana Industry

As more states legalize marijuana use, financial institutions face increased uncertainty about how to handle accounts opened by marijuana-related businesses (MRBs) in light of regulatory difficulties stemming from the obvious tension between state and federal law. Although the marijuana industry continues to rapidly grow, financial institutions have largely been sidelined by federal laws prohibiting the … Continue Reading

Don’t Roll the Dice: FinCEN Assesses Significant Penalties on Regulated Entity for Failing to Implement a Comprehensive AML Compliance Program

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) imposed a civil money penalty of $12 million against a Nevada based casino, CG Technology, L.P. (CGT) for alleged violations of the Bank Secrecy Act (BSA) on October 3, 2016. This action continues FinCEN’s recent trend of aggressive expansion and enforcement of anti-money laundering (AML) regulations … Continue Reading

Non-Federally Regulated Banks Are Target of Proposed FinCEN Rules

Last month the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed new rules which would require non-federally regulated banks to implement Customer Identification Program (CIP) requirements related to the collection and verification of customer information. Financial institutions have until October 24, 2016, to comment on the proposed rule, which, if adopted, is estimated to … Continue Reading
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