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ARTICLE · 22 JANUARY 2018

Considerations For Banks Given New Guidance On Cannabis

Duane Morris LLP
Duane Morris LLP
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In a January 4, 2018, memorandum regarding marijuana enforcement, U.S. Attorney General Jefferson B.

United StatesFinance and Banking
Arthur Coren
Arthur Coren
S. Alan Rosen
S. Alan Rosen
Jonathan Petrakis
Jonathan Petrakis
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The Attorney General's memorandum effectively changes federal prosecutorial policy but it did not change the fact that many states have legalized medical marijuana and/or adult-use marijuana.

In a January 4, 2018, memorandum regarding marijuana enforcement, U.S. Attorney General Jefferson B. Sessions rescinded, effective immediately, the previous guidance issued by the Department of Justice on marijuana, including the memorandum often referred to as the Cole Memo. To the extent a bank's compliance program relating to marijuana-related businesses (MRBs) relied on the guidance in the Cole Memo, the bank should immediately re-evaluate what changes in that program, if any, may be appropriate.  

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