| --- |
| title: "House Oversight: Estate Documents (Nov 12) (HOUSE_OVERSIGHT_024714)" |
| source: "House Oversight: Estate Documents (Nov 12)" |
| sourceUrl: "https://www.justice.gov/epstein" |
| date: "2026-01-01" |
| category: "House Oversight" |
| eftaNumber: "HOUSE_OVERSIGHT_024714" |
| ocrPages: 1 |
| ocrChars: 2500 |
| ocrElapsed: 0.0 |
| parseTier: "external-legacy" |
| engine: "engine undisclosed (ep-nov-12.greg.technology mirror)" |
| externalSource: "greg-ep-nov-12" |
| externalLicense: "not granted" |
| externalCredit: "ep-nov-12.greg.technology" |
| externalUrl: "https://ep-nov-12.greg.technology" |
| --- |
| |
| ACKRELL |
| CAPITAL |
| Cannabis Investment Report | December 2017 |
| 1. Verifying with the appropriate state authorities whether the business is duly licensed and |
| registered. |
| 2. Reviewing the license application (and related documentation) submitted by the business for |
| obtaining a state license to operate its marijuana-related business. |
| 3. Requesting from state licensing and enforcement authorities available information about the |
| business and related parties. |
| 4. Developing an understanding of the normal and expected activity for the business, including |
| the types of products to be sold and the type of customers to be served (for example, medical |
| versus recreational customers). |
| 5. Ongoing monitoring of publicly available sources for adverse information about the business |
| and related parties. |
| 6. Ongoing monitoring for suspicious activity, including for certain red flags described in the |
| FinCEN Memo. |
| 7. Refreshing information obtained as part of customer due diligence on a periodic basis and |
| commensurate with the risk. |
| The FinCEN Memo also guides financial institutions to file various SARs with FinCEN regarding |
| customers engaged in marijuana-related businesses. According to the memorandum, an institution |
| should file (i) a "Marijuana Limited" SAR for each customer it believes does not violate state law or |
| implicate any Cole Memo priority, (ii) a "Marijuana Priority" SAR for each customer it believes vio- |
| lates state law or implicates any Cole Memo priority, and (iii) a "Marijuana Termination" SAR if the |
| institution decides to terminate a customer relationship in order to maintain an effective anti-money |
| laundering compliance program. The FinCEN Memo outlines certain "red flags" that tend to indicate |
| which type of SAR filing is appropriate; red flags include the inability of a customer to demonstrate |
| compliance with state law or deposits of amounts of cash inconsistent with its tax returns. |
| FinCEN periodically publishes information about marijuana-related SAR filings made by deposi- |
| tory institutions. From the February 2014 FinCEN Memo publication through June 30, 2017, |
| Fin CEN received a total of 33,692 marijuana-related SAR filings from a total of 390 banks and credit |
| unions. The following graphs based on FinCEN data show the number of monthly Marijuana Limited, |
| Marijuana Priority and Marijuana Termination SAR filings for this period and the number of banks |
| and credit unions making such filings. |
| 78 |
| © 2017 Ackrell Capital, LLC | Member FINRA / SIPC |
| HOUSE_OVERSIGHT_024714 |
|
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