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September 26, 2016: Defining “Marijuana-Related Business,” ACAMS Today (sole author)
This article shares a comprehensive and cohesive framework for defining MRBs and for sorting general categories of MRBs into three risk-based tiers. Financial institutions, regulators and policymakers may find this framework useful when developing, revising or updating their marijuana-related policies and procedures.
September 28, 2015: Conflict & Uncertainty: Due Diligence Challenges for Marijuana-Related Businesses, ACAMS Today (co-authored with a Federal Reserve Senior Examiner)
Due to the legal quandary regarding “legalized” marijuana, financial institutions face unique challenges and considerations specific to marijuana-related businesses relative to other “legitimate” businesses. This article analyzes some of the questions financial institutions must ask themselves and the inherent risks they must be aware of when deciding whether to serve the marijuana industry.