GRN Holding Corp (GRNF)

[e-ore]

Gotta love Costello's I'm guilty of money laundering defense

"PBC and GRN are both MRB’s. Their businesses involve providing financial, investment and other services to Tier I MRB’s."

"The federal anti-money laundering statutes make it a crime to knowingly engage in monetary transactions involving proceeds of certain unlawful activity, including the sale of marijuana. Under these laws, all proceeds generated by MRBs (even if operating in compliance with state law) are unlawful, and financial transactions with such proceeds (including accepting deposits, making loans, and other banking services) constitute illegal money laundering."

“Because federal law prohibits the distribution and sale of marijuana, financial transactions involving a marijuana related business would generally involve funds derived from illegal activity. Therefore, a financial institution is required to file a SAR [“Suspicious Activity Report”] on activity involving a marijuana-related business (including those duly licensed under state law)…the decision to open, close, or refuse any particular account or relationship should be made by each financial institution based on a number of factors specific to that institution.... Thorough customer due diligence is a critical aspect of making this assessment.”

So every transaction that PBC processed on CANN's behalf should have generated a SAR by the financial institution that was holding the money "deposited" by CANN with PBC. Hawkins stated that money was at Chase bank. Chase should have refused to accept it, unless PBC hid the fact that it was MRB money.