In the last couple months of 2025, two major changes at the federal level will make 2026 a challenging year for financial institutions as they navigate their cannabis banking policies.
In November, as part of legislation to reopen the government, President Donald Trump signed a bill that will ban hemp-derived THC in 12 months, which will also impact nonintoxicating CBD products. Then, on Dec. 18, Trump issued an executive order to expedite the reclassification of marijuana from a Schedule I to Schedule III controlled substance. His order also calls on Congress to update the hemp-THC ban to allow for full-spectrum CBD products.
Before the executive order was signed, CRB Monitor CEO Steven Kemmerling discussed the potential impacts these changes would have on banking with Cogent Law attorney Chris Van Dyck in the webinar, “The State of Cannabis Banking for 2026: Rescheduling and the Future of Financial Compliance.”
In the one-hour webinar on Dec. 11, Steve and Chris examined:
- Whether hemp customers will suddenly fall under FinCEN banking guidance
- Should financial institutions reconsider their relationships with those customers
- Will FinCEN or other agencies issue new hemp-related banking guidance
- Whether rescheduling will impact BSA/AML compliance obligations
At this moment, there are more questions than answers. Listen to what Steven and Chris think may happen after talking to industry insiders and their recommendations for how banks and credit unions should proceed in the coming months.