Summarizing the challenges posed by marijuana-related banking.
This is CRB Monitor's first article, published in ACAMS Today in September 2015, which outlines the various, nuanced myths and realities of marijuana-related banking.
The article outlines and responds to a few of the key questions that Financial Institutions must consider, including:
- How does one define an “MRB?”
- “Are any of my existing or new customers MRBs themselves or are any of them exposed to any aspect of the marijuana industry via their customers?”
- If so, how do we manage the risk?
In this article, CRB Monitor Founder Steve Kemmerling first laid out the basic of his Tier 1, Tier 2, Tier 3 "Marijuana-Related Business" definition and risk framework, which was later written about in detail in Defining Marijuana-Related Business.