RLR Management Consulting

Cannabis Corner

Enhancing Your Compliance Program to Accommodate Cannabis Banking

Your financial institution is seeking new revenue streams and you’ve heard that Cannabis Banking can be a significant source.  You already have some clients that may be Cannabis Related Businesses (CRBs) and you want to make sure your Compliance Program, including BSA, is up to date with all of the current regulatory mandates.  Your state has legalized Cannabis (medical or recreational) and you want to make sure that these clients do not exist at your financial institution.  No matter where your financial institution stands on the subject of Cannabis Banking, your Compliance Program needs to be enhanced to address it.

RLR Management Consulting, Inc. has been writing, enhancing, and auditing Compliance Programs for financial institutions for over 30 years and we have been closely monitoring the Cannabis Banking environment and associated regulatory guidance.  Last year, we updated our BSA Audit Program to include guidance on Cannabis Related Businesses.  Further, through our ongoing research and analysis of Cannabis Banking we have concluded that a technology component that identifies tracks, monitors and manages cannabis related transactions is paramount to an FI’s success as they move forward with this new business venture. We have performed research on several Cannabis Technology vendors.

Are you scared? Intrigued? Something in between?

No matter what position your financial institution takes on the subject of Cannabis Banking, RLR Management Consulting, Inc. can assist you.  We can enhance your current BSA Program with Cannabis Banking elements to ensure regulatory compliance; review or audit your existing program and make recommendations for improvement or assist you in creating a Cannabis Banking Compliance Program adding a new source of revenue for your financial institution.  Contact us at [email protected] and let’s discuss the options.

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Additional Information

The CRB Program Risk Assessment will include a review of and guidance on:

  • Financial Institution’s Qualifications
    • Board of Directors Acceptance
    • Current BSA/AML Program
    • Financial Strength of the institution
    • Staffing and Expertise
    • Technology
  • Legal
    • Legal Consultation
    • Review of Federal and State guidance and City/County Ordinances
  • CRB Types and Enhanced Due Diligence
    • Tier Structure
    • CRB Owners and Employees
    • Hemp
  • Training
    • Board of Directors
    • BSA/AML Staff & Compliance Officers
    • Customer Facing Staff
  • BSA/AML Audit
    • Expertise, Scope, and Frequency
  • Competition and Potential
    • Other FIs Banking CRBs in Your Market Area
    • Reputation Potential
    • Market Potential
    • Revenue Potential
    • Liquidity Potential
  • Products and Services
    • Deposit Accounts
    • Lending
    • Online Banking
    • Cash Management
    • Debit/Credit Cards
    • Other Products and Services
  • Operations
    • Red Flags
    • Cole Memo Priorities
    • California DBO Guidance
    • CSBS Job Aid


Cannabis Policy’s by state