When it comes to your BSA/AML program, you need to conduct customer due diligence on all of your accounts. If you have marijuana-related business customers, they are obviously higher risk and will require more of your time and effort. One way to determine the level of customer due diligence is to break down the types of marijuana-related businesses you are dealing with.
Kevin explains more in the video.
Video Highlights:
- Customer due diligence is imperative for all accounts, and marijuana-related businesses are particularly high-risk.
- One method to determine the level of due diligence needed is by breaking the types of marijuana-related businesses down into tiers based on risk.
- Banks might choose to monitor the tiers differently, such as only banking certain tier companies and/or creating special procedures for them.
Published
2023/02/16
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).
