Green lets you rest at ease knowing that banking professionals that know the cannabis business have already navigated the complex world of compliance for Cannabis Related Businesses. Green’s purpose-built banking solution shields you and takes the burden of proof off your hands. Should you be called upon to prove that your business complies with all applicable financial regulations, we’ll be there to defend your interests and cooperate with authorities on your behalf.
The Financial Crimes Enforcement Network (“FinCEN”) issued guidance on February 14, 2014, called the “BSA Expectations Regarding Marijuana-Related Businesses” in an effort to clarify Bank Secrecy Act (“BSA”) expectations for financial institutions seeking to provide services to marijuana-related businesses.
How Does FinCEN Affect Dispensaries?
Besides facing criminal prosecution for drug trafficking, dispensaries must deal with further legal obstacles, which make operation challenging. One such barricade dispensaries face is finding banks, credit card companies, and payment processors willing to process the proceeds of cannabis transactions. Because the sale of cannabis remains outlawed under federal law, banks are placed in a position where they must report any banking transactions involving proceeds from cannabis dispensaries. Additionally, banks face the prospect of criminal penalties for aiding in money laundering should they knowingly accept and process funds from dispensaries. Due to these risks and possible punishments, banks have simply refused to do business with cannabis dispensaries.
The Cole Memo
After issuing guidance to federal prosecutors in 2009, new guidance was published in August 2013, by James M. Cole, the Deputy Attorney General. This new guidance regarding marijuana enforcement is currently written and referred to as the “Cole Memo.”
The Cole Memo is essentially a companion piece of guidance to FinCEN’s “BSA Expectations Regarding Marijuana-Related Businesses”. But rather than focusing on the specifics of how Banks can legally work with CRB’s, the Cole Memo addresses issues with respect to Prosecution of Drug Trafficking laws. It provides wide prosecutorial discretion on whether to prosecute state legal marijuana enterprises, and has implied that it is probably not efficient use of federal resources to center enforcement on state legal businesses.
Green removes the stress
of running your business
Green allows you to get back to the joy of running your business, without all the torture of dealing with cash or finding out once again your bank decided it was more risk than they were willing to take. Whether you’re a cash only operation dealing with armed transport, employee theft and the constant worry that comes with carrying lots of cash on hand, or looking to provide greater flexibility and options for your patients. Green solves all these problems and more.
Green is a robust processing solution with best-in-class security with the ability to comply with all regulatory frameworks.
We are a first-tier merchant processing cannabis industry pioneer, bringing to market the first and only comprehensive banking operation of its kind; a state-of-the-art system which tracks sales and tax collection, and empowers businesses with an advanced client management system.
Green’s elite product brings to market a groundbreaking merchant account with advanced processing perimeters, including the capabilities and security of accepting a traditional credit or debit card.
Is Green FinCEN and Cole Memo compliant?
Absolutely. The issuance of this guidance is in part, the very reason the opportunity for Green is so advantageous. Financial institutions largely have not opened their doors to legalized marijuana operations, because a due diligence regime is required as a contingency, and most financial institutions just don’t have those resources readily available. State Sourced has developed a unique proprietary system, enabling authorization to operate under these vital parameters.
A Robust Closed Loop Merchant Processing Brings to market private and encrypted digital Security to serve the Newly Legalized and Highly Regulated Sector
Tailored to deliver full-spectrum merchant processing services, Green empowers businesses and end users with the convenience of modern commercial card processing resources
Being the first and only comprehensive card processing operation of its kind, this cutting-edge system tracks sales and tax collection, and empowers businesses with an advanced client management system.
Green’s unique proprietary system enables authorized operation under FinCEN parameters, guidance issued to financial institutions serving the Cannabis Sector.
*Green is available only to licensed establishments as part of a state sanctioned cannabis system. Applicants must provide proof of licensure in their respective state.
We adhere to the guidance as laid out through the Cole Memo and the supplementary memo from Treasury.