Malka Levitin and Marc-Alain Galeazzi authored an article
for Bloomberg Law covering the current state of
the U.S. hemp regulatory regime, including the Financial Crimes
Enforcement Network's (FinCEN) recent guidance explaining how
Bank Secrecy Act (BSA) and anti-money laundering (AML) obligations
apply to hemp-related customers.
"Financial institutions and others considering doing
business with hemp companies should exercise caution and due
diligence and should continually monitor relevant laws,
regulations, and guidance, as these change regularly," the
authors wrote.
"Despite the risks posed by the rapidly changing and
sometimes unpredictable legal and regulatory environment, the
expanding hemp market offers substantial growth opportunities and a
potential early-mover advantage if marijuana is legalized at the
federal level, or, at a minimum, federal law is changed to permit
financial institutions to provide their services to MRBs in the
coming years," the
