Legal Seminar, Denver, CO
New Frontiers
• Marijuana. – Federal laws still present compliance challenges for those dealing with entities dealing in marijuana, even in states that legalize it. – “Marijuana Limited” vs. “Marijuana Priority” SAR filings under FinCEN guidance and the “Cole Memorandum” (2/14/14) • Should a customer relationship continue after a priority SAR is filed? • What about criminal liability for aiding and abetting?
New Frontiers • “Cole Memorandum” revoked; now, “weigh all relevant considerations, including federal law enforcement priorities set by the Attorney General, the seriousness of the crime, the deterrent effect of criminal prosecution, and the cumulative impact of particular crimes on the community.” Memorandum from Attorney General Sessions, January 4, 2018. • FinCEN indicates prior regime continues.
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