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

The Office of the Comptroller of the Currency (OCC) has revised its civil monetary penalty (CMP) policy, effective February 26, 2016. The revised Policy and Procedures Manual sets forth the OCC’s new scheme for the assessment of CMPs against national banks, federal savings associations, and bank service companies and service providers. The heart of the

Third Party Service Providers Remain in the SpotlightYesterday, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (the “Semiannual Risk Perspective”). The Semiannual Risk Perspective covers “key issues facing banks, focusing on those that pose threats to the safety and soundness of banks and their compliance with applicable laws and regulations.” While the OCC identifies four main