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Updated Hemp Guidance

8/4/2020

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By: Jeremy Clifton, CRCM, CAMS

On June 29, 2020, FinCEN issued guidance regarding due diligence requirements under the Bank Secrecy Act for Hemp-Related Business customers to address their expectations for banks with relationships with these types of businesses. The guidance outlines FinCEN’s minimum due diligence expectations which would include obtaining a copy of federal, state, and local licenses as applicable or an attestation that the customer is in compliance with such hemp regulations. FinCEN also noted that the due diligence was to be risk-based.  Therefore, it would be a good idea to conduct a basic risk assessment of any Hemp-Related Business to determine if further due diligence was needed.  The link below will direct you to the guidance issued by FinCEN.
 
FinCEN Guidance:

​https://www.fincen.gov/sites/default/files/2020-06/FinCEN_Hemp_Guidance_508_FINAL.pdf
​
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