Interest in cannabis is at an all-time high. In 2020, Americans bought $18.3 billion in cannabis products, a $7.6 billion increase from 2019. The surging popularity of the plant is running parallel to the move towards legalized cannabis. With the removal of hemp from the CSA controlled substance list, and as ever more jurisdictions broadly legalize cannabis products (with New York being the latest), some financial institutions are finding it more compelling to “go green.”
Continue Reading Financial Services in the Cannabis Industry: A Compliance Guide
Jeffrey Hare
Jeffrey is the Co-Chair of the Financial Regulation and Technology service group and operates out of the firm's Washington DC office. Jeffrey focuses his practice on federal and state banking and financial services laws and regulations.
In the financial services space, Jeffrey has significant experience with Bank Secrecy Act and anti-money laundering compliance, chartering and conversions, investor control issues, affiliated and insider transactions, mergers and acquisitions, product development, and permissible bank and holding company activities. He represents banks and lenders as well as their holding companies and investors in day-to-day compliance matters as well as examination criticism and enforcement actions.
Specific to anti-money laundering compliance, Jeffrey has developed and advised on implementation of clients' global programs. He has developed anti-money laundering programs for clients that are not directly subject to the Bank Secrecy Act but seek to adopt programs in order to address counter-party or bank demands, to reduce risk, or to satisfy industry expectations. He has also undertaken many comparative analyses of US anti-money laundering laws relative to those of foreign jurisdictions.
Having recently represented national trust banks in their formation and conversion, Jeffrey also has significant experience advising clients that offer trust, asset management and fiduciary services. In this regard, he has specific experience with federal preemption of state laws for trust banks and utilization of limited purpose trust companies within existing business organizations.
Further, Jeffrey has significant experience in consumer financial products, with specific focus on the Truth in Lending Act, Truth in Savings Act, Fair Credit Reporting Act, Real Estate Settlement Procedures Act, and fair lending laws. He has helped clients develop and implement compliance programs and customer disclosure materials for credit and deposit products.
With respect to non-bank clients specifically, he advises innovative payment service providers, money services businesses (including money transmitters and providers of prepaid access), vendors to banks, and retail merchants in connection with credit and debit card acceptance and co-brand agreements. Jeffrey has specific experience related to mobile payments and mobile banking and virtual currency.