2019-12-03
The Board of Governors of the Federal Reserve System, FDIC, FinCEN, and OCC issued a joint statement clarifying that banks are not required to file Suspicious Activity Reports for hemp customers solely due to their engagement in hemp cultivation. The guidance mandates that banks maintain BSA/AML compliance programs commensurate with risk, ensuring customers comply with USDA regulations and the 2018 Farm Bill while adhering to standard reporting procedures for suspicious activity. Banks are advised to continue following existing FinCEN guidance for marijuana-related businesses and to contact the USDA or FDA for questions regarding production regulations or product oversight.