Danielle Hunt

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In the wake of the shift in federal marijuana enforcement policy, financial institutions have been left to speculate the risk in offering financial services to marijuana-related businesses. While the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued guidance in 2014 that laid out a process for financial institutions to open accounts for marijuana-related businesses, that guidance was premised on the enforcement priorities of the Cole Memo. After last month’s rescission of the Cole Memo,…
Reiterating that Congress considers marijuana to be a “dangerous drug” and marijuana activity to be a “serious crime,” Attorney General Jeff Sessions today issued a memo to all U.S. attorneys rescinding various memoranda related to enforcement of federal marijuana laws issued during the Obama administration. Included in the rescinded memos was the prominent “Cole Memo,” which discouraged federal prosecution of anyone in compliance with the marijuana laws of their state. As we previously discussed,…
To date, eight states and the District of Columbia have legalized recreational marijuana. As you might expect, there are countless key players and businesses involved in the marijuana supply chain, including producers, processors, transporters, retailers, and in some jurisdictions, distributors. In Washington State alone, total sales since the state’s legalization of recreational marijuana have exceeded $1.5 billion. Generally speaking, the financial services industry has expressed mixed feelings about offering financial services to marijuana businesses.…