Alert! Marijuana and Hemp Accounts-Policy, Procedure and CIP Webinar

Credit Union penalized for Pot! What does it mean to banks and credit unions everywhere? What does your marijuana and hemp program contain? Do you know if you have marijuana or hemp related businesses?

What was in the consent order between credit union and NCUA? Here is what the credit union agreed to do.

The Credit Union consents to the following terms and conditions of the Order and to take the following actions:

  • A. Implement an automated system to effectively monitor and identify all transaction for suspicious activity in accordance with 31 C.F.R. 1020.210(a)(2)(v)(B), by April 30, 2021, and ongoing. Your automated compliance and suspicious activity monitoring system must include functions to support your compliance with FinCEN requirements for Marijuana-Related Businesses (‘€œMRB’€). At a minimum, this includes:
    • 1. Reconciliation of MRB Point of Sale, METRC, or accounting system data relative to member deposits.
    • 2. Ongoing monitoring of adverse public information affecting MRBs.
    • 3. Timely verification of changes in licensure status, including notification of a lapse in an MRB’s state licensure.
    • 4. Systematic monitoring of unusual Automated Clearing House or wire activity for MRB accounts.
    • 5. Monitoring of FinCEN “Red Flags” outlined in FIN-2014-G001, “BSA Expectations Regarding Marijuana-Related Businesses.”
  • B. Engage a third party to validate your automated compliance and suspicious activity monitoring system simultaneously with the implementation of this system.
  • C. Immediately file all Suspicious Activity Reports (‘€œSARs’€) in accordance with 31 C.F.R. §1020.320. This includes continuous and initial MRB SARs. Develop and implement a system to ensure all SARs are filed accurately, completely, and on time by March 31, 2021.
  • D. Immediately develop and implement a system to ensure all Currency Transaction Reports are filed accurately in accordance with 31 C.F.R. §1020.311.
  • E. Immediately cease opening new MRB accounts.
  • F. Cease your Money Services Business (‘€œMSB’€) program by March 15, 2021. This includes suspending transactional activity on existing MSB accounts.
  • G. Engage a qualified third party to perform a retrospective review of your MSB activity to determine the existence of suspicious activity warranting a SAR filing by March 15, 2021. At a minimum, the review must evaluate the criteria outlined in FIN- 2019-A003, “Advisory on Illicit Activity Involving Convertible Virtual Currency.” File any SARs recommended by the third party.

Be proactive. Ignoring the industry won’€™t help your organization. You need policy and procedures even if you decide not to bank marijuana and hemp customers.


Components of a marijuana and hemp program
When do you have to file SARs?
What should be in your policy, your procedures and your questionaires
What should you do if you don’€™t want to bank marijuana but you do want to bank hemp?
Make your risk assessment

Who Should Attend?

Compliance Officers, BSA Officers, New Accounts, Branch Administration, Security, Training and HR.

Continuing Education (CE) Credits

This webinar is recommended for 2.5 CE Credit Hours. Each attendee will receive a Certificate of Attendance for self-reporting of CE Credits.

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Deborah Crawford
Deborah Crawford

Deborah Crawford is the President of Gettechnical Inc., a Virginia based training company. She specializes in the deposit side of the financial institution and is an instructor on IRAs, BSA, Deposit R... read more.

Course TitleCreditsStart DateStart TimeDelivery TypeDelivery OptionInstructor / LocationPrice
Alert! Marijuana and Hemp Accounts-Policy, Procedure and CIP0.25 Any AnyWebinarSix Month On-Demand Recording Deborah Crawford$295.00 Register Now
Alert! Marijuana and Hemp Accounts-Policy, Procedure and CIP0.25 Any AnyWebinarCD-ROM Video Recording Deborah Crawford$345.00 Register Now
Delivery Options

INCLUDES 7 DAYS OF ONDEMAND PLAYBACK! With this option, you will participate in the webinar (via the internet) as it is being presented. You will login to the webinar on your PC to view the PowerPoint presentation, and you have the option of using your PC speakers or a telephone for the audio. You can type and send your questions to the instructor. Many companies are now running their PC through an LCD projector allowing many employees to participate at the same time. And don’t worry if you miss the webinar, you can still view it for up to seven days after it takes place!

With this option, you will receive an e-mail that contains a link to the PowerPoint slides (to download, print, and copy) as well as a link to the media player where you will view and hear the entire webinar just as it was delivered, featuring the full-color PowerPoint presentation with audio. You can pause, fast-forward and rewind as needed, which makes it an effective training tool. The weblink will be available to you (and anyone else in the company) for up to six months and can be accessed 24/7 as many times as you wish. Delivered via e-mail the day after the webinar takes place.

If you do not have internet access or want to make the webinar part of your training library, the CD-ROM Recording is a great option for viewing a webinar. You can pause, fast-forward and rewind as needed, which makes it an effective training tool. With this option, you will receive a download of the PowerPoint slides and a CD-ROM Recording (featuring PowerPoint presentation with audio) of the webinar via regular mail. Mailed 7 to 10 days after the webinar takes place.

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