GRN Holding Corp (GRNF)

[DWillie]

I was reading one of those sites I that do cannabis banking and they mentioned that the Cole Memorandum, in part, gave them legal authority to conduct MRB transactions.

https://www.hypur.com/cole-memo-recscission-one-year-later/

Because all moneys generated by marijuana commerce are considered criminal proceeds for purposes of federal money laundering and Bank Secrecy Act (AML/BSA) laws, even in states where marijuana is legal, financial institutions were understandably reluctant to service MRBs.

In an attempt to bridge this seemingly insurmountable gap the Cole Memo offered banks the following deal: if they and their MRB customers adhered to relevant state law and did not implicate any of DOJ’s eight priority enforcement factors, such as selling marijuana to minors or diverting marijuana proceeds to gangs or cartels, they would effectively be immune from AML/BSA laws.

For its part, FinCEN established a new Suspicious Activity Report (SAR) regime explicitly for banks serving MRBs that mirrored the eight priority enforcement factors contained in the Cole Memo. In that respect, the FinCEN guidance was regarded as being dependent upon, and a supplement to, the Cole Memo, which was universally considered to be the cornerstone of marijuana banking.

Taken together, the message of the Cole Memo and FinCEN guidance was that AML/BSA laws do not constitute a barrier to financial institutions serving MRBs. Over time that message began to take hold, as banks and credit unions across the country started accepting MRB accounts.