Regulatory Alerts2020-06-15
Idaho Department of Finance Guidance on BSA Expectations for Marijuana-Related Businesses
The Idaho Department of Finance issued guidance statement 2020-06-FIB to direct state-chartered banks and credit unions on complying with Bank Secrecy Act obligations when serving marijuana-related businesses. The document incorporates FinCEN's FIN-2014-G001 framework, requiring rigorous customer due diligence and the filing of specific Suspicious Activity Reports categorized as Limited, Priority, or Termination based on compliance with state law and federal enforcement priorities. Examiners will utilize these standards to assess institutional risk management, particularly regarding red flags such as revenue discrepancies, licensing failures, or activities implicating the Cole Memo priorities.
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