Deputy Seminar, Denver, CO

How To Comply? Due Diligence at Account Opening Verify license status and business registration. Review license application. Develop understanding for normal and ongoing Monitoring Review publicly available information periodically. Look for potentially suspicious activity consistent with red flags described. Refresh information obtained as part of customer due diligence on a periodic basis and commensurate with risk. Expected activity for the business. Cole Memorandum Priorities 1. Prevent distribution to minors; Primary Method: Site visits and surveillance conducted by LCB. 2. Prevent revenue from going to criminal enterprises, gangs, and cartels; Primary Method: LCB application process and transaction monitoring by Bank 3. Prevent diversion of marijuana from states where it is legal under state law in some form to other states; Primary Method: Traceability system monitored by LCB. 4. Prevent state-authorized activity from being used as a cover for trafficking of other illegal drugs or illegal activity;

Primary Method: Traceability system monitored by LCB and transaction monitoring by bank.