To Bank or Not to Bank: Compliance Considerations When Deciding Whether to Serve the Cannabis Industry


To date, more than 30 U.S. states have legalized marijuana for either medical or recreational use; however, cultivation, possession, and the sale of marijuana remains illegal on a federal level.. In this session, learn about the history of regulatory guidance around the cannabis industry, the recent rescission of the “Cole Memorandum,” and the implications of this action by the current administration on the banking industry. Explore the decision-making structure surrounding policies unique to each institution.

Learning Objectives:

  • Learn strategies for identifying clients who may be operating as growers or sellers of cannabis, known as Marijuana-Related Businesses (MRBs) and for properly vetting clients that serve the industry but who do not directly “touch the plant”
  • Consider possible definitions for MRBs and ancillary businesses based on industry guidance to determine  appropriate client acceptance policies and monitoring procedures
  • Understand the legal and regulatory uncertainty that exists in the wake of the rescission of the Cole Memo and its priorities for prosecution, as well as the FinCEN guidance for SAR filings on MRBs.


Laurel Sykes
Vice President & Chief Risk Officer
Montecito Bank & Trust 

Laurel Sykes is senior vice president and chief risk officer of Montecito Bank & Trust. Her career includes over 25 years of experience in financial services and risk management. In her current position, she is responsible for consumer compliance, Bank Secrecy Act/OFAC/anti-money laundering compliance, fraud investigation/prevention, information security, business continuity, exam management, and enterprise risk management.  She teaches financial literacy in local schools and offers cybersecurity workshops for small businesses, non-profits and industry groups.  She shares the role of board-appointed information security officer for the bank. Laurel is also responsible for implementing the bank’s award-winning elder financial abuse awareness program


WiBinar Fees

Pricing For Price Season Pass
Bank Member $195 $0
Bank Nonmember $249 $0
Affiliate Member $195 $0
Affiliate Nonmember $249 $0

Season Pass Members receive 4 individual logins to every WiBinar:

This WiBinar is ideal for:

Chief Compliance Officer, Chief Risk Officer, Operational Risk Officer, Bank Counsel, Risk Manager, Fraud Manager, BSA Officer