California Regulators Issue Cannabis Banking Guidance That’s Actually Useful

On October 2, 2019, the California Department of Business Oversight issued some really helpful guidance aimed at California banks and credit unions that are currently or are planning to bank marijuana-related businesses (MRBs). The guidance document consists of an extensive questionnaire that is used by California state bank examiners when they audit a bank or credit union’s MRB compliance program. The guidance document is intended to help California financial institutions comply with Bank Secrecy Act and FinCEN guidance on cannabis banking. Although some of the guidance in the questionnaire is California-law specific, much of it is broadly applicable to any financial institution in any state that has legalized medical or recreational cannabis. We are encouraging all of our financial institution clients who have or are working on MRB compliance programs to take a look!