Cannabis Banking Law
Many financial institutions are struggling to know whether they should serve cannabis businesses and if so, how. Why is this? They cannot find someone to bridge the gap between what many external counsel do, which is providing legal advice regarding serving a federally illegal market, and what BSA/CRB software companies do, which is providing ready-made software designed to manage the risk of serving these businesses. What they need is someone who can not only provide practical advice on the risks and rewards of cannabis banking but who can also provide a clear roadmap for implementing such a program and, importantly, making the program sustainable and profitable. As an attorney, a former financial regulator, and a BSA officer who has developed and overseen a highly successful BSA/CRB banking program, Chris Van Dyck is uniquely qualified to bridge that gap.
CHRIS VAN DYCK
Chris Van Dyck, a partner at the Cogent Law Group, has been involved in the cannabis banking space for close to ten years, first as a financial regulatory attorney and then as general counsel and BSA officer at a financial institution. During his time as a regulatory attorney, he worked closely with financial institutions regulated by his office on compliance issues, including cannabis banking when the FinCEN guidance was issued in 2014. For the last nine years, he has focused his attention on developing a cannabis banking program, ensuring that it meets all regulatory expectations. During his tenure, the cannabis banking program at his financial institution grew extensively and became a significant revenue source.
Available Services
- Board / Senior Management Presentations
- Interpreting 2014 FinCEN Guidance
- CRB Policies and Procedures
- CRB Onboarding
- CRB SAR Reporting Requirements
- CRB Due Diligence
- BSA Staff Training
- Examiners’ Expectations
- CRB Strategic Planning
- Return On Investment / Fees
- CRB Risk Assessments
- Examination Support
Because of his extensive experience in this area, both as a regulator and BSA officer, Chris is uniquely qualified to advise your financial institution on starting its own successful cannabis banking program, ensuring that it adequately manages the risks associated with these accounts, developing policies and procedures that adequately reflect adherence to the 2014 FinCEN guidance, and advising on ways in which to effectively implement these policies and procedures. Chris is also able to advise on practical ways your financial institution will be able to gain traction in this sector, maintaining and growing your customer base, while generating significant revenue.