Every indexed document

and failure to satisfy that obligation may result in civil or criminal penalties. Information

a federal agency charged with enforcing federal securities laws.

the State Treasurer’s Office recommended the

indicate cannabis businesses increasingly are accessing

692 marijuana-related SAR filings from a total of 390 banks and credit

and (iii) a “Marijuana Termination” SAR if the

(ii) a “Marijuana Priority” SAR for each customer it believes violates

including for certain red flags described in the

suspects or has reason to suspect that a transaction conducted or attempted by

a suspicious activity report (SAR) if the financial

tax or regulatory proceedings or in government intelligence

including the federal money laundering statute

the FDA has not published detailed guidance about its cannabis-related enforcement

including FDA resources and threats to public health. Beyond

the FDA may consult with its federal and state

and suggests certain steps to address those challenges. The guidance

due to the unique nature of botanical drugs

Sativex or Epidiolex). The FDA publication does not demonstrate that neither

based on the FD&C Act provisions cited by the FDA

and by pursuing injunctions and criminal prosecutions.