DoJ rescinds marijuana enforcement directives, could impact CUs' BSA compliance
U.S. Attorney General Jeff Sessions yesterday rescinded directives that had instructed federal prosecutors to ease marijuana enforcement in states that have legalized the substance. The change in federal drug enforcement priorities creates additional legal and compliance challenges for credit unions serving marijuana-related businesses.
Two of the rescinded directives include the Cole memos, which were issued in August 2013 and February 2014 by then-Deputy Attorney General James Cole to address enforcement in states that had legalized and regulated marijuana. Based on the Cole memos' enforcement posture, the Financial Crimes Enforcement Network (FinCEN) issued guidance to clarify Bank Secrecy Act (BSA) expectations for financial institutions providing services to marijuana-related businesses.
As FinCEN's BSA guidance depended heavily on these now-retracted enforcement directives, the legal and compliance risks associated with serving marijuana-related businesses become more uncertain.
NAFCU has resources available on its Compliance Blog and has explored the issue in its monthly Compliance Monitor newsletter to help credit unions understand the compliance risk of serving marijuana businesses. The association's compliance team will provide members with an update on the rescinded directives' implications next week.
Add to Calendar 2020-02-04 14:00:00 2020-02-04 14:00:00 Challenges Your CU Will Face When Leasing or Buying a Branch Fixed assets are often one of the largest items in a credit union's budget. Branches or headquarters buildings are very costly, and Board of Directors and Management should use caution when spending member’s money. 2020 should be the year of the tenant and credit unions will have the opportunity to negotiate some amazing lease deals or renew their existing lease(s) and take advantage of the savings. Acquiring an existing building or branch will be a challenge, but this webinar will provide best practices on how to navigate the process. During this webinar, we’ll also highlight many of the options that credit unions have for acquiring a new building as well as walk through comprehensive checklists for leasing and purchasing. Several examples of how credit unions have succeeded or failed with acquiring new buildings will also be addressed. Key Takeaways Discuss lease issues and alternatives such as renew, recast, renovate and relocate Review comprehensive checklists for due diligence, purchase, and closing Learn more about decision matrix for new premises as well as current premises Walk through lists of regulatory issues and legal aspects of fixed assets Analyze case study examples Purchase Now$295 Members | $395 Nonmembers (Additional $50 for CD)One registration gives your entire credit union access to the on-demand recording until February 4, 2021.Already registered? Go to the Online Training Center to view live. Who Should Attend? Presidents and Chief Executive Officers Chief Operating Officers Chief Financial Officers Facilities Managers Internal Auditors Board of Directors and Supervisory Committee Credit Union staff attorneys Education Credits NCVEs will receive 1.5 CEUs for participating in this webinar. CPA credit information is below; recommended 1.5 CPE credits. CPA Certification Credit Information Reviewer: Josie Collins, Education Manager, NAFCU Learning Objectives: Discuss lease issues and alternatives such as renew, recast, renovate and relocate. Review comprehensive checklists for due diligence, purchase, and closing. Learn more about decision matrix for new premises as well as current premises. Walk through lists of regulatory issues and legal aspects of fixed assets. Analyze case study examples. Program Level: Basic Prerequisites Needed: None Advance Preparation Needed: None Delivery Method: Group Internet-Based Recommended CPE Credits: 1.5 credits Recommended Field of Study: Management Services - Technical National Association of Federal Credit Unions (NAFCU) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. Learn more. About Our Webinars Our webinars are streamed live from NAFCU headquarters near Washington, D.C. Your audio/video feed of the presenters includes presentation slides and downloadable handouts. You can easily submit your questions to the presenters at any time during the live broadcast, with no dialing over the phone! The audio and video stream directly through your computer. Web NAFCU email@example.com America/New_York public
Credits: NCVE, CPE
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