Regulatory Alerts2014-02-14
BSA Expectations Regarding Marijuana-Related Businesses
The Financial Crimes Enforcement Network issued guidance clarifying Bank Secrecy Act obligations for financial institutions providing services to marijuana-related businesses. The document requires institutions to conduct rigorous customer due diligence against eight Department of Justice enforcement priorities and mandates the filing of Suspicious Activity Reports for all such transactions. It establishes specific SAR categories, including Marijuana Limited, Marijuana Priority, and Marijuana Termination, to align reporting with federal law enforcement goals.
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