Compliance

Federal Regulatory Framework

• FinCEN Guidance (2014): Permits banks to serve cannabis-related businesses in states with legal cannabis programs, subject to enhanced due diligence and SAR filing requirements.
• Cole Memorandum priorities: Though formally rescinded, these enforcement priorities remain the de facto compliance benchmarks applied by banking partners.
• SAFE Banking Act: We monitor federal legislative progress and our compliance program is designed to remain valid under both current law and anticipated reform.

BSA / AML Program

• Designation of a qualified BSA/AML Compliance Officer
• Written policies and procedures for suspicious activity detection
• Ongoing transaction monitoring for structuring and unusual patterns
• Currency Transaction Report (CTR) filing for cash transactions over $10,000
• Suspicious Activity Report (SAR) filing as required, including marijuana-specific SARs
• Annual independent testing of the compliance program
• Ongoing employee training

KYC & Merchant Onboarding

Every merchant account undergoes rigorous Know Your Customer (KYC) and Know Your Business (KYB) verification, including state cannabis license verification, beneficial ownership identification for all 25%+ owners, government-issued ID, bank account verification, OFAC screening, and site inspection.

State-Level Compliance

MMJPay maintains current knowledge of cannabis banking regulations in all states where we operate. Contact [email protected] with state-specific questions.

Merchant Compliance Obligations

• Maintain all required state and local cannabis licenses in good standing
• Notify MMJPay immediately of any license suspension, revocation, or regulatory action
• Cooperate with all reasonable documentation requests from our compliance team
• Operate only within the scope of your licensed activities
• Maintain age verification systems in compliance with state law

Compliance Contact

Email: [email protected]  |  Regulatory inquiries: [email protected]