The Bank Secrecy Act and related federal and state law requirements are the first line of defense against financial crimes, and financial institutions play an important role in minimizing these risks. It is important that financial institutions are able to effectively identify, monitor and communicate Bank Secrecy Act/Anti-money Laundering (“BSA/AML”) risk. For many institutions, particularly small, non-complex institutions, these requirements command significant compliance resources.
DFI's Division of Banks recently answered a question regarding DFI's position on indirect banking of marijuana-related businesses. See the document linked below for more information.
On February 14, 2014, the Department of the Treasury, Financial Crimes Enforcement Network, issued Guidance FIN-2014-G001, “BSA Expectations Regarding Marijuana-Related Businesses.” Boards and management teams of our state-chartered financial institutions should carefully review this guidance and discuss it with legal counsel when considering whether and how to provide banking services to I-502 compliant entities and individuals and/or whether to accept I-502 tax proceeds for transmission to the Washington State Department of Revenue.