Federal Bank Regulators Issue Guidance on Serving Hemp-Related Businesses
by Michael G. Dailey, Jennifer K. Mason, Ambur C. Smith
Published: December, 2019
Submission: December, 2019
On Dec. 3, 2019, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the Financial Crimes Enforcement Network (FinCEN) and the Office of the Comptroller of Currency (OCC) in conjunction with the Conference of State Bank Supervisors (CSBS) issued a joint statement entitled “Providing Financial Services to Customers Engaged in Hemp-Related Businesses.” Aside from summarizing the United States Department of Agriculture’s (USDA) recently published interim final rules for domestic hemp production, the statement attempts to clarify the legal status of hemp growth and production in light of the Bank Secrecy Act (BSA) and corresponding regulations. The following are key takeaways from the statement.
USDA Interim Final Rules for Domestic Hemp Production
See additional guidance on the USDA’s interim final rules for domestic hemp production here.
Banks should also anticipate further guidance from FinCEN related to serving hemp-related businesses.
Distinguishing Treatment of Marijuana-Related Businesses
If you are a financial institution interested in serving hemp-related businesses or have already begun doing so, contact your Dinsmore attorney to discuss the impact of this statement on your current and future practices.
Find the entire joint statement here.
Link to article
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