Deputy Seminar, Denver, CO

FinCEN Guidance - SARs

Three new kinds of SARs Marijuana Limited Marijuana Priority Marijuana Termination

Framework is intended for direct MRBs as evidenced by footnote 7.

provided indirectly, the financial institution may file SARs based on existing regulations and guidance without distinguishing between Marijuana Limited and Marijuana

Direct MRB Indirect MRB

Your customer sells, processes, or grows marijuana Maintains deposit or lending relationship with the bank

Your customer transacts business with a direct MRB Examples: Leases space to direct MRB

Sells products or services to direct MRB Employed by direct MRB