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Prior to joining CLA, he served as managing director at a top-10 accounting firm and as the compliance officer of a large financial institution, where he developed and implemented its first regulatory compliance program.
, to clarify Bank Secrecy Act expectations for financial institutions seeking to provide services to marijuana-related businesses.
He assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, training staff on regulations, and performing website compliance assessments.
In addition, John is a frequent speaker at industry conferences and state associations.
As noted in the cannabis Guidance, the updated SAR “may contain the same limited content as the initial SAR, ” (emphasis added).
However, if, in the course of conducting customer due diligence (including ongoing monitoring for red flags), the financial institution detects changes in activity that potentially implicate one of the Cole Memo priorities or violate state law, the financial institution should file a “Marijuana Priority” SAR.Fin CEN’s Cannabis Guidance was an attempt to reconcile compliance with the SAR filing requirement for suspicious criminal activity with the Obama Administration’s decision to deemphasize prosecution of cannabis-related business, provided that the cannabis activity was lawful under the laws of a particular state.Following due diligence by a financial institution, a bank account could be opened for a cannabis-related entity, but a Marijuana Limited SAR was required to be filed with Fin CEN.We recently received confirmation from Fin CEN that financial institutions continue to be required to update their Suspicious Activity Reports (“SARs”) on marijuana-related businesses – a requirement that is being missed by some financial institutions.This Alert addresses the continuing obligation by financial institutions providing banking services to participants in the cannabis industry to regularly update “Marijuana Limited” SAR filings.