CBD OIL

Kind Idaho Chair Jackee Winters is laser-focused on qualifying the group’s medical cannabis legalization initiative for the state’s 2022 ballot in order to help her daughter, who suffers from a brain tumor, get legal access to cannabis.

“It’s time for Idaho to grow up,” she told Cannabis Business Times and Cannabis Dispensary. “There are people here who suffer, and we’re behind the times. We need medical advancements in Idaho, and I don’t want to have to relocate my entire family. … It’s not fair that she’s got to suffer, and they basically try to turn us all into criminals by not letting us have our own choice.”

Winters said Kind Idaho has a “skeleton crew” of volunteers in different parts of the state, and has collected roughly 5,000 of the 65,000 total signatures needed to get the group’s medical cannabis legalization measure, the Idaho Medical Marijuana Act for 2022 (IMMA), before voters next year.

IMMA would legalize the possession of up to 4 ounces of cannabis for medical purposes, as well as the home cultivation of up to six plants for patients with a “hardship waiver.” The measure would also create a system of dispensaries to sell medical cannabis to qualified patients in the state.

“We’re asking for regulated medication—cannabis—that would be available to [patients] when they need it,” Winters said. “We really need something … for the people in Idaho who suffer.”

Recruiting volunteers has been challenging, Winters said, and speculated that people simply may not be familiar with the Kind Idaho campaign.

“People may not know of us because it’s our first time doing this, or [word] hasn’t gotten out there,” she said.

Kind Idaho just finished a push to gather signatures at Hempfest, an educational event held Aug. 14 in Boise, and plans to send volunteers to upcoming fairs in the state.

“We just keep trucking along, wishing for the best,” Winters said.

The Idaho Way, formerly known as the Idaho Citizen Coalition for Cannabis, is also working to bring cannabis policy reform to Idaho in the form of a decriminalization initiative called the Personal Adult Marijuana Decriminalization Act (PAMDA).

PAMDA would not create a commercial adult-use cannabis industry in Idaho, but would legalize the personal possession of up to 3 ounces of cannabis in private for adults 21 and older.

Like Kind Idaho, The Idaho Way is currently in the process of collecting roughly 65,000 signatures to place PAMDA on Idaho’s 2022 ballot.

RELATED: Idaho Cannabis Advocates Launch Legalization Efforts in ‘The Most Hostile State’ Toward Policy Reform

During its last legislative session, the Idaho Legislature passed S.B. 1110, which changed the signature-gathering requirements for groups like Kind Idaho and The Idaho Way to get their measures before voters.

Under Idaho’s previous law, which went into effect in 2013, campaigns had to collect signatures from 6% of the registered voters in 18 of Idaho’s 35 legislative districts. Under S.B. 1110, they must gather signatures from 6% of registered voters in all 35 districts to qualify their initiatives for the ballot, which Winters said is “virtually impossible.”

Kind Idaho submitted IMMA before the new law took effect, allowing the campaign to qualify its initiative with signatures from 18 of the state’s districts, while The Idaho Way had to operate under the new law and gather signatures from all 35 districts.

Reclaim Idaho, a campaign behind a ballot initiative for Medicaid expansion, sued over S.B. 1110 in May, and the Idaho Supreme Court ruled Aug. 23 that the new law is unconstitutional, according to an Idaho Statesman report.

In its ruling, the Supreme Court said the law infringed on the public’s right to enact laws outside of the Legislature, and that both the Legislature and the Secretary of State’s Office “failed to present a compelling state interest for limiting that right,” the news outlet reported.

Kind Idaho and The Idaho Way were both watching the case closely.

“Should the decision go in Reclaim’s favor, and the law returns with the 18-district threshold, then we’ll be moving forward with our PAMDA initiative,” Russ Belville, a spokesman for The Idaho Way, told Cannabis Business Times and Cannabis Dispensary earlier this month. “If it doesn’t go in our favor and we’re stuck with 35 districts, we’ll probably fold the PAMDA initiative and put all our efforts into the IMMA medical initiative.”

Winters said Belville had been helping the Kind Idaho campaign prior to launching the PAMDA initiative, and the two groups are continuing to work together as much as possible.

“Everyone working together is how we’re going to get this done,” she said, adding that she is gathering signatures alongside Kind Idaho’s volunteers. “I’m actually out there in my community getting signatures because it’s very important to Idaho and I want to be part of this changing of times, making history in Idaho.”

It’s no secret that many of California’s legal cannabis businesses have been struggling to thrive since the state launched its first adult-use sales in 2018.

To help support the industry, the County of Humboldt launched Project Trellis in 2019 as a three-tier initiative that provides business support and resources to the industry, covering cannabis business micro-grants, local equity, and marketing and promotion.

“It was created through a resolution that provided 10% of our local cannabis cultivation taxes to be returned to the community through this project,” said Peggy Murphy, economic development specialist for the County of Humboldt. “It covers three basic programs.”

The Micro-Grant Program offers grants of up to $10,000 for cannabis and ancillary businesses—including cultivators, retailers, distributors and manufacturers—for projects approved by the Project Trellis Committee. The grants are competitive, and applications go through the committee for scoring and ranking.

In its first year, Project Trellis awarded $180,000 in microgrants, and in its second year, it awarded $519,000. The grants have funded a variety of projects, Murphy said, including business’ organic certifications, water tanks and solar panels.

The Local Equity Program is based off California Senate Bill 1294, which encouraged the state’s counties to create a Cannabis Equity Assessment, and then a local equity program, in order to apply for state funds to support local equity programs.

Humboldt County ultimately won three awards—one from the Bureau of Cannabis Control (BCC) for $1.3 million and two from the Governor’s Office of Business and Economic Development for $2.4 million and $1.05 million.

Murphy said Project Trellis initiated its Local Equity Program using the original BCC award and is in the final stages of contracting with those awardees.

Project Trellis launched an updated version of its equity program, “Version 2.0,” on Aug. 16, using the second award of $2.4 million and incorporating feedback from the community, stakeholders and funders.

Finally, the county-wide Marketing and Promotion Program aims to promote and maintain Humboldt-grown cannabis as a national and industry brand.

Qualifications for each program vary, Murphy said. Applications for the annual Micro-Grant Program were built in-house by the Project Trellis Committee and staff with oversight from the Project Trellis Board of Directors.

To qualify for a grant, a business must be operating in the cannabis industry, either as a startup or an established company.

“If your project includes finishing your establishment—like completing your permitting and licensure—then we will consider you, but it is really geared toward established cannabis businesses,” Murphy said.

Businesses must be licensed and registered to operate in Humboldt County, with at least 75% of their operations based in Humboldt County, in order to qualify for a grant.

In any given year, Murphy said Project Trellis receives approximately 70 applications for the Micro-Grant Program. During the first year, it funded 17 projects, and during the second year, it funded 16.

To qualify for the Local Equity Program, business owners must be at or below a certain income level, reside in Humboldt County, and be a shareholder or owner with at least 20% interest in a cannabis business. Once all those qualifications are met, applicants must meet a minimum of another set of criteria, including items such as minority ownership.

“A good amount of what we deal with is compliance-related, or conditional [license] approval, and that’s true for both the Micro-Grant as well as the Local Equity Program,” Murphy said. “I think overall, not just our program but the community itself, recognizes that the cost of becoming legitimate within the commercial cannabis marketplace is extreme, and with the fluctuations in the market, it’s incredibly tough even for those who have gone completely through the [licensing] process.”

Project Trellis Committee meetings are open to the public, and the program also hosts public town halls (now conducted via Zoom due to the ongoing COVID-19 pandemic) to receive feedback from the local community.

“We’re really intended to be there to help support the cannabis industry,” Murphy said. “I think that’s important to state because I think a lot of times, people assume that because we are the County of Humboldt, we aren’t necessarily looking out for their best interests. And we’re hoping to be an advocate for the community.”

ACS Laboratory, a cannabis and hemp testing lab based outside of Tampa Bay, Florida, announced the launch of their “Tested Safe Certified Seal” program. The program is designed to help raise standards and put more consumer trust in safe, tested products.

ACS Laboratory is an ISO 17025-accredited and DEA-licensed cannabis testing company founded in 2008. Last year they were certified by the Florida Department of Health to perform cannabis testing for state-licensed cannabis companies. In addition, the company acquired Botanica Testing, Inc. in 2020, adding more than 500 hemp and CBD clients to their portfolio. They now perform hemp testing for clients in more than 44 states.

The “Tested Safe Certified Seal” program allows companies to adorn their products with the trademarked seal following testing, informing consumers that their product has met safety standards and a full panel of compliance tests. “Unlike a mandated QR code that links to a Certificate of Analysis (COA) with detailed test results, the Seal shows visual proof at a glance that consumers can trust a brand,” reads the press release.

The program is also endorsed by the American Cannabinoid Association (ACA). “It is exciting to see our industry legally providing cannabis and cannabis-derived products on a commercial scale,” says Matthew Guenther, founder of the ACA. “As with any consumer product, safety and quality control remain our absolute priority.”

To earn the seal, companies send their products to the ACS lab for a full panel of safety and potency tests. ACS has a scope of services that includes: potency testing for 21 cannabinoids, 38 terpene profiles, 42 residual solvents, screening for 105 pesticides, moisture content, water activity, microbiology panels, heavy metals screening, flavonoid testing for 16 profiles, micronutrient testing, mycotoxins, Vitamin E acetate, shelf life & stability, plant regulators (PGRS), PAH testing and Pharmacokinetic Studies (PK) aka human trials.

It’s no secret that many of California’s legal cannabis businesses have been struggling to thrive since the state launched its first adult-use sales in 2018.

To help support the industry, the County of Humboldt launched Project Trellis in 2019 as a three-tier initiative that provides business support and resources to the industry, covering cannabis business micro-grants, local equity, and marketing and promotion.

“It was created through a resolution that provided 10% of our local cannabis cultivation taxes to be returned to the community through this project,” said Peggy Murphy, economic development specialist for the County of Humboldt. “It covers three basic programs.”

The Micro-Grant Program offers grants of up to $10,000 for cannabis and ancillary businesses—including cultivators, retailers, distributors and manufacturers—for projects approved by the Project Trellis Committee. The grants are competitive, and applications go through the committee for scoring and ranking.

In its first year, Project Trellis awarded $180,000 in microgrants, and in its second year, it awarded $519,000. The grants have funded a variety of projects, Murphy said, including business’ organic certifications, water tanks and solar panels.

The Local Equity Program is based off California Senate Bill 1294, which encouraged the state’s counties to create a Cannabis Equity Assessment, and then a local equity program, in order to apply for state funds to support local equity programs.

Humboldt County ultimately won three awards—one from the Bureau of Cannabis Control (BCC) for $1.3 million and two from the Governor’s Office of Business and Economic Development for $2.4 million and $1.05 million.

Murphy said Project Trellis initiated its Local Equity Program using the original BCC award and is in the final stages of contracting with those awardees.

Project Trellis launched an updated version of its equity program, “Version 2.0,” on Aug. 16, using the second award of $2.4 million and incorporating feedback from the community, stakeholders and funders.

Finally, the county-wide Marketing and Promotion Program aims to promote and maintain Humboldt-grown cannabis as a national and industry brand.

Qualifications for each program vary, Murphy said. Applications for the annual Micro-Grant Program were built in-house by the Project Trellis Committee and staff with oversight from the Project Trellis Board of Directors.

To qualify for a grant, a business must be operating in the cannabis industry, either as a startup or an established company.

“If your project includes finishing your establishment—like completing your permitting and licensure—then we will consider you, but it is really geared toward established cannabis businesses,” Murphy said.

Businesses must be licensed and registered to operate in Humboldt County, with at least 75% of their operations based in Humboldt County, in order to qualify for a grant.

In any given year, Murphy said Project Trellis receives approximately 70 applications for the Micro-Grant Program. During the first year, it funded 17 projects, and during the second year, it funded 16.

To qualify for the Local Equity Program, business owners must be at or below a certain income level, reside in Humboldt County, and be a shareholder or owner with at least 20% interest in a cannabis business. Once all those qualifications are met, applicants must meet a minimum of another set of criteria, including items such as minority ownership.

“A good amount of what we deal with is compliance-related, or conditional [license] approval, and that’s true for both the Micro-Grant as well as the Local Equity Program,” Murphy said. “I think overall, not just our program but the community itself, recognizes that the cost of becoming legitimate within the commercial cannabis marketplace is extreme, and with the fluctuations in the market, it’s incredibly tough even for those who have gone completely through the [licensing] process.”

Project Trellis Committee meetings are open to the public, and the program also hosts public town halls (now conducted via Zoom due to the ongoing COVID-19 pandemic) to receive feedback from the local community.

“We’re really intended to be there to help support the cannabis industry,” Murphy said. “I think that’s important to state because I think a lot of times, people assume that because we are the County of Humboldt, we aren’t necessarily looking out for their best interests. And we’re hoping to be an advocate for the community.”

Cannabis is still federally illegal and is included on Schedule 1 of the Controlled Substances Act (CSA), along with such other substances as heroin, fentanyl and methamphetamines.¹ It is a federal crime to grow, possess or sell cannabis.

Despite being federally illegal, 36 U.S. states and the District of Columbia have legalized the sale and use of cannabis for medical and/or adult use purposes,² and both direct and indirect cannabis-related businesses (CRBs) are growing at a rapid rate. Revenue from medical and adult use cannabis sales in the US in 2019 is estimated to have reached $10.6B-$13B and is on track to reach nearly $37B in 2024.³

Because the sale of cannabis is federally illegal, financial institutions face a dilemma when deciding to provide services to CRBs. Should they take a significant legal risk or stay out of the market and miss out on a significant revenue opportunity? So far, the vast majority of financial institutions have been unwilling to take the risk, resulting in a dearth of options for CRB’s. Until recently, cannabis business operators had few options for financial services, but times are changing.

This piece will discuss current trends in banking for cannabis-related businesses. We will cover differences in legality at state and federal levels, complexities in dealing in cash versus digital currencies, Congressional actions impacting banking and CRBs and how banking is changing. The explosion of state legalization of cannabis over the past several years has had a strong ripple effect across the US economy, touching many industries both directly and indirectly. Understanding the implications of doing business with a CRB is both challenging and necessary.

Feds Versus States

Money laundering is the process used to conceal the existence, illegal source or illegal application of funds.⁴ In 1986 Congress enacted the Money Laundering Control Act (MLCA), which makes it a federal crime to engage in certain financial and monetary transactions with the proceeds of “specified unlawful activity.”⁵ Therefore, CRB transactions are technically illegal transactions under the MLCA.

Financial institutions therefore face a risk of violating the MLCA if they choose to do business with CRBs, even in states where cannabis operations are permitted. In addition, financial institutions could also face criminal liability under the Bank Secrecy Act (BSA) for failing to identify or report financial transactions that involve the proceeds of cannabis businesses operating legally under state law.⁶

In short, because cannabis is illegal at the federal level, processing funds derived from CRBs could be considered aiding and abetting criminal activity or money laundering. States, however, began legalizing cannabis in 1996, and by 2009, thirteen states had laws allowing cannabis possession and use.⁷ Despite this legislation, federal authorities continued to aggressively enforce federal cannabis laws.⁸ That changed under the Obama administration when, shortly after being elected, President Obama stated that his administration would not target legal CRB’s who were abiding by state laws.[9] In an attempt to provide clarity in this murky environment, beginning in 2009, the Department of Justice (DOJ) issued three memos designed to guide federal prosecutors in this area. However, none of the DOJ memos issued from 2009 through 2013 addressed potential financial crime related to the legal sale or distribution of cannabis in states allowing the use of medicinal or recreational cannabis.

To assist financial institutions in navigating potential financial crime implications of banking CRBs, the Financial Crimes Enforcement Network (FinCen) issued guidance in 2014 that clarified how financial institutions could conduct business with CRBs and maintain compliance with their Bank Secrecy Act requirements (2014 Guidance).⁹ According to the 2014 Guidance, financial institutions may choose to interact with CRBs based on factors specific to each institution, including the institution’s business objectives, the evaluated risks associated with offering such services, and its ability to manage those risks effectively.

The 2014 Guidance requires those who choose to provide services to CRBs to design and implement a thorough customer due diligence review that includes, in part, analyzing the licensing of the entity, developing an understanding of the business operations of the entity, and ongoing monitoring of the entity.⁹ In addition, financial institutions are required to file a Suspicious Activity Report (SAR) for every transaction they process for a CRB, should they choose to accept the business.

Although the 2014 Guidance does outline a path for financial institutions to engage with CRBs, it does not change federal law and, therefore, does not eliminate the legal risk to financial institutions.¹⁰ By its very nature, the 2014 Guidance was a temporary fix, subject to changing views of different administrations, evidenced by the fact that all three of the DOJ guidance documents noted above were rescinded by then Attorney General Jeff Sessions on January 4, 2018.¹² The DOJ enforcement posture could change once again in a Biden administration. Biden is on record as favoring decriminalization, and Attorney General candidate Merrick Garland has stated that if confirmed he will deprioritize enforcement of low-level cannabis crimes. Garland also believes using limited government resources to pursue prosecution of cannabis crimes states where cannabis is legal does not make sense.¹²

Because of the uncertainty and high risk, most banks remain unwilling to serve CRBs. Those that do serve CRBs charge exorbitant fees (fees of $750-$1,000 or more per account per month are not uncommon), pricing many smaller operators out of the financial services market.

Cash is King – Or Is It?

Cannabis operators have discovered the old adage “cash is king” is not necessarily true when it comes to the cannabis space. Bank-less CRBs are forced to utilize cash to pay business expenses, which can be particularly difficult. Utility companies, payroll companies, and taxing authorities are just some of the providers that are difficult, if not impossible, to pay in cash. For example, cannabis operators have been turned away from IRS offices when attempting to pay large federal tax obligations in cash. Likewise, cannabis operators have been unable to utilize payroll processing companies to administer payroll and benefits for their businesses because the processors won’t take cash. CRBs can’t use Amazon or other online retailers because online providers cannot accept cash.

Because dealing in cash is so difficult, CRB operators look for workarounds such as using personal credit/debit cards to purchase business equipment and supplies. This doesn’t eliminate the cash problem, however, because the credit card holder will likely have to accept cash as reimbursement. Such transactions could be considered an attempt to hide the source of the cash, which is, by definition, money laundering.

Some bank-less CRBs try to skirt the system by obtaining bank accounts in the name of management companies or other entities one step removed from the actual business. While operators often choose this route in an effort to streamline business and operate out of the shadows, it again runs afoul of banking laws. Transferring cannabis related financial transactions to another entity is actually the very definition of money laundering – which, as noted above, is defined as the process used to conceal the existence or source of “illegal” funds.

In addition to the difficulties in making payments or purchasing business supplies, operating in a cash-heavy environment poses significant safety risks for cannabis operators. CRBs often have large sums of money onsite and transport large sums of cash when purchasing product or paying bills, making them a target for robbery. In 2017, there was a spate of dispensary robberies across the Phoenix Metro area, including one at Bloom Dispensary that took place during operating hours.¹³

Managing all that cash increases the cost of doing business as well, in the form of increased labor, insurance, and security costs. Cash must be counted and double counted, which can be time consuming for staff, not to mention the time it takes to deliver physical cash payments to hither and yon. Ironically, lack of banking significantly decreases transparency and clouds the waters of compliance, as operating strictly in cash makes it easier to manipulate reported financial results.

Potential Congressional Solutions

In recent years Congress has undertaken several efforts to pass legislation designed to address the state/federal divide on cannabis, which would likely clear the way for financial institutions to provide services to CRBs, including:

• R. 1595 – Secure and Fair Enforcement Banking Act of 2019 (“SAFE Act”);
• 1028 & H.R. 2093 – Strengthening the Tenth Amendment Through Entrusting States Act (STATES Act); and
• 2227 – Marijuana Opportunity Reinvestment and Expungement Act of 2019 (MORE Act).

The climate in Washington DC, however, did not allow any of these initiatives to pass both houses of congress. Had any been sent to the White House, President Trump was unlikely to sign them into law.

The cannabis industry has new reason to believe reform is on the horizon with shift in political leadership in the White House and Senate. Newly anointed Senate Majority Leader Chuck Schumer recently committed to making federal cannabis reform a priority, and President Biden appears committed to decriminalization, reviving the hope of passage of one of these pieces of legislation.

The Changing Banking Landscape

Even though there is little in the way of formal protections for financial institutions, and with the timeline for a legislative fix unknown, an increasing number of banks are working with cannabis operators.

According to FinCen statistics, there were approximately 695 financial institutions actively involved with CRBs as of June 30, 2020. It is important to note that these statistics are based on SAR filings, which banks are required to file when an account or transaction is suspected of being affiliated with a cannabis business. However, some of these SARs may have been generated on genuine suspicious activity rather than on a transaction with a known cannabis customer.

There are arguably more banking institutions offering services to CRBs than ever before. The challenges for CRBs are (1) finding an institution that is willing to offer services; (2) building/maintaining a compliance regime that will be acceptable to that institution; and (3) cost, given the high fees associated with these types of accounts. 

How CRBs Get Accepted by Banks

The gap between CRBs’ need for banking and the financial services providers’ sparse and expensive offerings to the sector has created an opportunity for third-party firms to intervene and provide a compliance structure that will satisfy the needs of the financial institutions, making it easier for the CRB to find a bank.

These third-party firms perform extensive BSA-compliant due diligence on applicants to ensure potential customers are following FinCen guidance required to receive banking services. After the completion of due diligence, they connect the CRBs with financial institutions that are willing to do business with CRBs and provide checking/savings accounts, check writing capability, and merchant processor accounts. These firms often provide additional services such as armored car and cash vaulting services. Some of these firms also offer vendor screening, pre-approving vendors before any payments can be made.

One such firm, Safe Harbor Private Banking, started as a project implemented by the CEO of Partners Credit Union in Denver, Colorado, who set out to design a cannabis banking program that would allow Partners to do business with Colorado CRBs.¹⁵ The program was successful and has since expanded into other states who have legalized cannabis. Other operators include Dama Financial and NaturePay.

While these services offer hope for many CRBs, the downside is cost. These services perform the operations necessary to find, open, and maintain a compliant bank account; however, the costs of compliance are still high, pricing some small operators out of the market.

Is Digital Currency an Answer?

 Digital currency is also making its way into the cannabis world. Digital currency, or cryptocurrency, is a medium of exchange that utilizes a decentralized ledger to record transactions, otherwise known as a blockchain. One of the largest benefits of blockchain is that it is a secure, incorruptible digital ledger used for, among other things, financial transactions.¹⁶ Blockchain technology offers CRBs a transparent and immutable audit trail for business and financial transactions. Several cannabis-specific cryptocurrencies have sprung up in the past several years, including PotCoin, CannabisCoin, and DopeCoin, to name a few.

In July 2019, Arizona approved cryptocurrency startup ALTA to offer services to the state’s medical cannabis operators.¹⁷ ALTA describes itself as a “digital payment club where cash-intensive businesses pay each other using digital tokens instead of cash.”¹⁸ ALTA members purchase digital tokens that are used to pay other members using a proprietary blockchain based system. The tokens are redeemable for US dollars at a stable rate of 1:1, and CRBs do not need a bank account to participate in the ALTA program.

ALTA proposes to pick up members’ cash and exchanges it for tokens, which are then used to pay other members for goods and services. Tokens may be redeemed for cash at any time.¹⁸ The company has been approved by the Arizona State Attorney General, and one of the first members they hope to enlist is the Arizona Department of Revenue (ADOR). Enlisting ADOR into the program would allow dispensary members to pay state taxes digitally rather than hauling large amounts of cash to ADOR offices.

Similarly, Nevada recently contracted with Multichain Ventures to supply a digital currency solution to the Nevada cannabis industry. Nevada Assembly Bill 466 requires the state create a pilot program to design a “closed loop” system like Venmo in an effort to reduce cash transactions in the cannabis sector. Like ALTA, Nevada’s proposed system will convert cash to tokens which can then be transacted between system participants.¹⁹

While both proposals are promising for Arizona and Nevada CRBs, the timeline as to when, or if, these offerings will come online is unknown. Action on cannabis reform at the federal level may render these options moot.

Looking to the Future

Although states are legalizing cannabis in one form or another in growing numbers, the fact that cannabis is still federally illegal poses a significant barrier to accessing the financial services market for CRBs. While most banks are still reluctant to offer services to this rapidly growing industry, there are more banks than ever before willing to participate in the cannabis industry. Recent changes in leadership in Washington DC offer a positive outlook for cannabis reform at the federal level.

As the “green rush” continues to envelop the country, financial services options available to CRBs are slowly growing. Many new options are now available to help CRBs find a bank, develop compliance programs, and manage the cash related problems encountered by most CRBs. However, these solutions may be out of reach for the budget-conscious small operator. Also, there are a number of cryptocurrency solutions designed specifically for CRBs; however, when, or if, these solutions will gain significant traction is still unknown.

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References

1. Controlled Substances Act, 21 U.S.C., Subchapter I, Part B, §812.
2. “State Marijuana Laws”; National Conference of State Legislatures, February 19, 2021.
3. “Exclusive: US Retail Marijuana Sales On Pace to Rise 40% in 2020, near $37B by 2024”. Marijuana Business Daily, June 30, 2020.
4. Kaufman, Irving. “The Cash Connection: Organized Crime, Financial Institutions, and Money Laundering”. Interim Report to the President, October 1984.
5. S. Code § 1956 – Laundering of Monetary Instruments.
6. Rowe, Robert. “Compliance and the Cannabis Conundrum.” ABA Banking Journal, September 11, 2016.
7. “History of Marijuana as a Medicine – 2900 BC to Present”. ProCon.org, December 4, 2020.
8. Truble, Sarah and Kasai, Nathan. “The Past – and Future – of Federal Marijuana Enforcement”. org, May 12, 2017.
9. FIN-2014-G001, BSA Expectations Regarding Marijuana-Related Businesses.
10. Cannabis Banking Coalition Statement.
11. Sessions, Jefferson B. “Memorandum for All United States Attorneys”. January 4, 2018.
12. “Attorney General Nominee Garland Signals Friendlier Marijuana Stance”. Marijuana Business Daily, February 22, 2021.
13. Stern, Ray. “Robbers Hitting Phoenix Medical Marijuana Dispensaries: Is Bank Reform Needed?” The Phoenix New Times, April 11, 2017.
14. FinCen Marijuana Banking Update, June 30, 2020.
15. Mandelbaum, Robb. “Where Pot Entrepreneurs Go When the Banks Just Say No.” The New York Times, January 4, 2018.
16. Rosic, Ameer. “What is Blockchain Technology? A Step-by-Step Guide for Beginners.” com, 2016.
17. Emem, Mark. “Marijuana Stablecoin Asked to Play in Arizona Fintech Sandbox.” CCN.com, October 25, 2019.
18. http:\Whatisalta.com
19. Wagner, Michael, CFA. “Multichain Ventures Secures Public Sector Contract with Nevada to Supply Tokenized Financial Ecosystem for the Legal Cannabis Industry”, January 26, 2021.