DISCLAIMER: The Department of Financial Institutions does not provide legal advice. This information is provided for guidance purposes only.

DFI FAQs and Information

Liquor and Cannabis Board Rule

Federal Guidance

The Cole Memorandum: Guidance Regarding Marijuana Related Financial Crimes (the Cole Memorandum) was issued by the U.S. Department of Justice on 8/19/2013, by Deputy Attorney General James Cole. The Cole Memorandum served as a guide to the exercise of federal investigative and prosecutorial discretion.

FinCEN responded to the Cole Memorandum by issuing interpretive guidance entitled BSA (Bank Secrecy Act) Expectations Regarding Marijuana-Related Businesses on 2/14/2014.  The Cole Memorandum was rescinded by Attorney General Jeff Sessions in January of 2018, but the FinCEN guidance remains in effect.  The established expectations and reporting procedures for financial institutions providing services to cannabis related businesses are outlined in that interpretive guidance.

The eight enforcement priorities that were set forth in the Cole memorandum are the underpinning of the FinCEN guidance, and also inform rules adopted by the Washington State Liquor and Cannabis Board.  

See: FinCEN Guidance: Bank Secrecy Act Expectations Regarding Marijuana-Related Businesses

Hemp-Related Businesses