Know Where to Start
You've decided to bank the cannabis industry, now what? Consider the internal and external resources, especially partners with expertise and experience banking with MRBs, partners that can help you deliver on these six critical items:
POLICIES & PROCEDURES
It's important to update your BSA\AML policies and procedures to reflect the enhanced regulatory requirements and the unique aspects of the industry. Consider the policy and procedure ramifications for account opening and closing not to mention branch cash handling procedures.
INTERNAL & EXTERNAL TRAINING
Driving the right customer outcomes begins with training your employees to understand your MRB banking program, their role and the expectations to which customers are held. Compliance and efficiency are impacted by the data provided by customers. Train your teams to perform.
UNDERWRITING & ONBOARDING
Many FIs decline 50% or more the applications they received from MRBs. A clear underwriting process assures you have the best operators and can quickly disengage from quick prospects that are unlikely to meet your business requirements.
Understanding the cash transactions is simply not enough to assure compliance. Develop data collection methods that provide 100% transparency into all financial transactions including in-depth information about counterparties.
Regularly check with state licensing authorities to ensure the MRB is operating within the guidelines established for your state.
VERIFICATION & VALIDATION
Develop methods and processes not only to collect data from multiple sources but reconcile that data to find anomalies and assure all financial activity is in compliance.