Malka Levitin and Marc-Alain Galeazzi authored an article for Bloomberg Law covering the current state of the U.S. hemp regulatory regime, including the Financial Crimes Enforcement Network's (FinCEN) recent guidance explaining how Bank Secrecy Act (BSA) and anti-money laundering (AML) obligations apply to hemp-related customers.
"Financial institutions and others considering doing business with hemp companies should exercise caution and due diligence and should continually monitor relevant laws, regulations, and guidance, as these change regularly," the authors wrote.
"Despite the risks posed by the rapidly changing and sometimes unpredictable legal and regulatory environment, the expanding hemp market offers substantial growth opportunities and a potential early-mover advantage if marijuana is legalized at the federal level, or, at a minimum, federal law is changed to permit financial institutions to provide their services to MRBs in the coming years," the authors added.
Read the full article.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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