Deputy Seminar, Denver, CO

Cole Memorandum 2 nd Memo Issued in February 2014 addresses provide services to MRBs operating in compliance with state laws and eight priorities.

implicate any of the eight priority factors, prosecution for these offenses may not be appropriate

services to a marijuana-related business knowing that the business is diverting marijuana from a state where marijuana sales are regulated to one where such sales are

U.S.C § § 1956, 1957, 1960 or the BSA might be

FinCEN Clarifying Guidance Issued February 2014 (same day as 2 nd Cole Memo) to clarify how provide services to MRBs consistent with BSA obligations Refers directly to the Cole Memo priorities must conduct customer due diligence and perform ongoing monitoring to assess compliance with Cole Memo Priorities