Answer:
Absolutely, FinCEN rules on this are explicit. There are 3 different types of SARs that apply solely to cannabis customers:
Marijuana Limited: based on the bank’s due diligence, the cannabis customer is not doing anything illegal. This filing documents the existence of the business and has particular content requirements. It must be routinely reported every 90 days;
Marijuana Priority: bank due diligence indicates activity that implicates one of the “8 Priorities” from the Cole Memo or otherwise violates state law; or
Marijuana Termination: To preserve an effective AML program, the bank gave the business the boot.
Learn more about these 3 SAR categories, along with a host of other crucial cannabis banking information at the upcoming webinar “Top 10 Cs of Cannabis Compliance” on February 21, 2024!
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