Regulatory Alerts2019-01-17
Guidance for Banks Regarding Marijuana Derived Products
The Kansas Office of the State Bank Commissioner issued this memorandum to address banking inquiries regarding marijuana and marijuana-derived products amidst conflicting state and federal laws. The document outlines the legal landscape, noting that while Kansas has legalized CBD and hemp, federal law still prohibits marijuana, leaving the FinCEN Guidance as the primary regulatory framework for financial institutions. Banks are instructed to review FinCEN's eight federal priorities, file specific Suspicious Activity Reports for marijuana-related transactions, and consult legal counsel due to the ongoing uncertainty in the regulatory environment.
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