Talk:Cole Memorandum

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Scans?

Resolved

I wonder if we could get scans of the docs by Cole or Sessions? ---Another Believer _(Talk) 01:28, 5 January 2018 (UTC)[reply]

@Bri: Wow, you are fast! ---Another Believer _(Talk) 02:27, 5 January 2018 (UTC)[reply]

Banking under Cole

Proposed text and perhaps a graph to add in a new section for the relationship between Justice and Treasury. There's actually a whole lot of sources out there, enough for expansion way beyond what I put here.

Banking regulations issued by the United States Department of the Treasury Financial Crimes Enforcement Network (FinCEN) in 2014 referred to the Cole Memo and both "clarifie[d] how financial institutions can provide services to marijuana-related businesses" and provided regulated banks and credit unions a list of "red flags" for any activity that "implicates [non-compliance with] one of the Cole Memo priorities".^[1] Under the 2014 FinCEN guidance, hundreds of U.S. banks and credit unions were allowed to provide banking services to the marijuana industry by 2017.^[2] Based on information received from Department of the Treasury to a newspaper's public records request, in 2017 a single credit union in Seattle had over 300 such customers.^[3] As of the date of the 2018 Sessions memo, industry did not have new guidance from Treasury Department.^[4] Politico stated on the day Sessions' memo was issued that the 2014 FinCEN guidance "remains on the books".^[5] On January 11, 2018, FinCEN issued a brief statement that the 2014 banking guidance "remains in place".^[6]

References

^ BSA Expectations Regarding Marijuana-Related Businesses
^ Marijuana banking update through Q1 2017 (PDF), United States Department of the Treasury Financial Crimes Enforcement Network (FinCEN)
^ Lester Black (April 19, 2017), "The Credit Unions and Small Banks That Solved the Cannabis Cash Crisis", The Stranger, Seattle
^ Robert McVay (January 5, 2018), "What You Need to Know Now: An Analysis of the Sessions Marijuana Memo", Canna Law Blog, Harris Bricken Law Group
^ "Sessions announces end to policy that allowed legal pot to flourish: DOJ leaders said the Obama-era policies made marijuana industry players too comfortable.", Politico, January 4, 2018 {{citation}}: Unknown parameter |authors= ignored (help)
^ "FinCEN Retaining Bank Secrecy Act Marijuana Guidance — At Least for Now", JD Supra (blog), Lane Powell PC, January 11, 2018 – via Lexology

[1] BSA Expectations Regarding Marijuana-Related Businesses

[2] Marijuana banking update through Q1 2017 (PDF), United States Department of the Treasury Financial Crimes Enforcement Network (FinCEN)

[3] Lester Black (April 19, 2017), "The Credit Unions and Small Banks That Solved the Cannabis Cash Crisis", The Stranger, Seattle

[4] Robert McVay (January 5, 2018), "What You Need to Know Now: An Analysis of the Sessions Marijuana Memo", Canna Law Blog, Harris Bricken Law Group

[5] "Sessions announces end to policy that allowed legal pot to flourish: DOJ leaders said the Obama-era policies made marijuana industry players too comfortable.", Politico, January 4, 2018 {{citation}}: Unknown parameter |authors= ignored (help)

[6] "FinCEN Retaining Bank Secrecy Act Marijuana Guidance — At Least for Now", JD Supra (blog), Lane Powell PC, January 11, 2018 – via Lexology

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