GrayRobinson Regulated Products Section Chair and Cannabis Law Team Leader Richard Blau Presents During The Rossdale Group CLE

March 15, 2023

GrayRobinson Regulated Products Section Chair and Cannabis Law Team Leader Richard Blau today presented during the “Mastering Marijuana, CBD, and Hemp Business Law in 2023” CLE presented by The Rossdale Group, a national leader in attorney education. Blau addressed current issues and practical solutions relating to federal and state law compliance in transactional, investment, banking, money laundering, and commercial relationships involving marijuana-related businesses (MRBs). He explained that a wide range of service providers are subject to substantial regulatory scrutiny if they work directly or indirectly with MRBs. For reference, financial service providers include not only banks (31 CFR §1020.320) and bank and financial holding companies (12 CFR § 225.4) but also casinos and card clubs doing business with MRBs (31 CFR § 1021.320), money services businesses working with MRBs (31 CFR §1022.320), brokers or dealers trading in securities related to MRBs (31 CFR § 1023.320), and mutual funds invested in MRBs (31 CFR §1024.320). Blau also detailed the interplay between financial service providers working with MRBs and the compliance responsibilities, such as Suspicious Activity Reports (SARs) and Currency Transactions Reports (CTRs) imposed by federal regulators, which include the following:


  • The Financial Crimes Enforcement Network (FinCEN);
  • The Federal Reserve Board (FRB);
  • The Federal Deposit Insurance Corp. (FDIC);
  • The Office of Comptroller of Currency (OCC); and
  • The Conference of State Bank Supervisors (CSBS).