Cannabis banking program

A cannabis banking program is the set of policies, controls, systems and staff a bank or credit union uses to serve cannabis-related businesses while meeting Bank Secrecy Act requirements.

What a cannabis banking program is

A cannabis banking program is the set of policies, controls, systems and staff a bank or credit union puts in place to serve cannabis-related businesses while meeting Bank Secrecy Act requirements and FinCEN's 2014 guidance.

What a program includes

Risk assessment and approval: a documented decision by leadership and the board on risk appetite and limits.
Onboarding: license verification, ownership checks and enhanced due diligence.
Monitoring: ongoing review of account activity against expected activity and state records.
Reporting: marijuana-specific SARs and CTRs.
Cash logistics: arrangements for armored transport and vault processing.
Staffing and audit: trained staff and independent testing of the program.

Why it matters

Cannabis deposits can be a meaningful source of funding, but the compliance work is specialized and constant. Institutions either build a program in house or work with a partner that manages much of it for them.

What to look for in a partner

A long record of exams and audits with cannabis accounts.
Clear division of responsibilities between the institution and the partner.
Onboarding, monitoring and reporting support that scales with deposits.

How Safe Harbor helps

Safe Harbor offers a fully managed cannabis banking program for banks and credit unions, covering compliance, onboarding, client support and program management.