2020-02-05
The Office of Financial Institutions (OFI) issued this bulletin to clarify state and federal regulatory frameworks for financial institutions banking cannabis and hemp-related businesses, detailing FinCEN Suspicious Activity Report (SAR) requirements and operational red flags. Institutions must align their anti-money laundering compliance programs with these standards by correctly classifying transactions as Marijuana Limited, Priority, or Termination and maintaining standard currency reporting thresholds. By adhering to these guidelines and consulting legal counsel, financial institutions can effectively manage federal marijuana prohibitions while supporting legitimate state-authorized commercial activities.