The decision to bank marijuana-related businesses creates additional steps for banks regarding their Bank Secrecy Act (BSA) practices.
In today’s economy, the number of businesses that are involved, one way or another (directly or indirectly), in cannabis and marijuana-related activity is continuously growing. Naturally, this means that more and more financial institutions are deciding to bank marijuana-related businesses (MRB).
The decision to bank an MRB creates additional steps for the bank regarding its Bank Secrecy Act (BSA) practices. While not exhaustive, here are a few items that will need to be addressed if banking MRBs.
- Cannabis Risk Assessment
- AML/CFT Risk Assessment
- Policy/Procedures
- Customer Due Diligence
- Monitoring for Suspicious Activity
- SAR filings
- Staff Training
If you are banking MRBs, are you sure your BSA/AML/CFT audit is sufficient based on your bank’s risk?
The purpose of independent testing (audit) is to assess the bank’s compliance with BSA regulatory requirements, relative to its risk profile, and assess the overall adequacy of the BSA/AML compliance program. Independent testing of specific BSA requirements should be risk-based and evaluate the quality of risk management related to ML/TF and other illicit financial activity risks for significant banking operations across the organization. Risk-based independent testing focuses on the bank’s risk assessment to tailor independent testing to the areas identified as being of the most significant risk and concern. – FFIEC BSA/AML Examination Manual.
CCI can provide you with the security of a well-rounded BSA/AML/CFT independent audit that includes your bank’s cannabis program. Reach out today to schedule your 2026 audit at the 2025 price!
Reach us at (402) 939-6715 or inquiries@completecompli.com.
Steve Doty, CRCM, CBP