We do not provide services to the cannabis industry.
West Coast AML Services was created to manage the unique challenges of banking state-licensed marijuana-related businesses* (MRBs) and minimize the possibility of prosecution under federal money laundering statutes (18 U.S.C. §§ 1956 and 1957) and regulatory enforcement actions. We prepare risk assessments focused on U.S. Department of Justice enforcement priorities and create the structure, policies, procedures and controls of risk management programs within the context of BSA/AML compliance specific to marijuana-related businesses. We recommend enhancements to existing programs, tailor training for BSA officers and senior management, and advise the Board on oversight.
West Coast AML Services crafts risk assessments focused on U.S. Department of Justice enforcement priorities, FFIEC regulatory expectations and state regulatory enforcement environments. Our assessments include risk management considerations pertaining to ancillary accounts, which are those accounts held by individuals and entities that are not involved in the production, distribution, transportation or sale of marijuana but who provide lawful goods and services to MRBs. We present the risk assessment to the financial institution's Board of Directors and provide the board with cannabis banking BSA training.
West Coast AML Services provides AML subject matter expertise to identify, mitigate and manage compliance risks associated with the development and strategic implementation of MRB banking programs. Our firm prepares risk assessments and creates the structure, policies, procedures and controls of risk management programs within the context of BSA/AML compliance. We "kick-start" MRB banking programs and guide financial institutions through the ever-changing challenges of banking the state-legal cannabis industry.
West Coast AML Services examines compliance programs with firsthand insight into the prosecution of financial institutions and bankers by the Department of Justice. Our firm has practical knowledge from regulator examinations of MRB compliance programs we created and existing programs we enhanced. We recommend program enhancements, provide training to BSA staff and advise the board on effective program oversight.
Our training department offers a pilot program stakeholders forum consisting of SME presentations on managing the unique compliance risks of MRB banking, the Federal landscape surrounding MRB banking, and the cannabis industry – license application to banking relationship.
West Coast AML Services has assisted us with our high-risk cannabis portfolio for years. They have provided invaluable insights, without which, we would not have understood how to successfully improve our risk mitigation. Training they provide is outside the mainstream BSA training available and has assisted us with being far more effective managing our high-risk portfolio.
Safe Harbor Services
Partner Colorado Credit Union
Annual cannabis-related deposits:
2019 $2.531 billion / P2020 $3.338 billion
As an attorney that specializes in finance and banking, finding qualified professionals and experts to assist in my practice is ever-important. When dealing with regulatory issues and the hyper-scrutinized cannabis banking regulations, near-perfection is a prerequisite. West Coast AML Services and its principals are always my first call when it comes to these critical issues. Compliance for financial institutions has little room for error and West Coast AML Services understands this high standard and meets it.
West Coast AML Services is experienced, up-to-date, professional and easy to work with. This makes working with them a pleasure and their work-product reflects well on them, on me and my clients.
WCAMLS crafted a risk assessment that methodically described how Pacific Valley Bank intended to identify, evaluate and manage the various risks associated with banking the state-legal cannabis industry and indirect account holders. The firm's managing director, Terry Neeley, worked closely with my BSA Officer developing our corresponding policy and procedures and then effectively presented it to our Board. My bank is fortunate to have engaged WCAMLS rather than try to navigate the murky and challenging waters on our own.
West Coast AML Services has been instrumental in navigating the complex regulatory landscape of cannabis banking. They have a deep understanding of the risks involved and proper “ risk mitigation strategies. I have worked with West Coast across two financial institutions and their services have been a big factor in the success of the cannabis programs.
The West Coast AML Services team members have been true professionals and have always made themselves readily available for consultation. I would highly recommend West Coast AML Services to any financial institution that may have a cannabis program, is considering a cannabis program, or has decided not to offer services to the cannabis industry. A well-developed program is critical for the financial institution and West Coast AML Services is the best resource to assist in this task.
Since our initial work with West Coast AML Services in early 2018, we continue to improve our program in ways we didn’t know we could. From practical tips on cannabis business behaviors, to better monitoring programs, our documentation and evaluation of our cannabis businesses is better, more accurate and safer than ever before. West Coast AML Services’ insight is impeccable and straightforward. We are proud to have them on our compliance team.
For states such as California that have enacted laws to authorize the production, distribution and possession of marijuana, the Department of Justice expectation is that these states would establish strict regulatory schemes that protect the federal enforcement priorities. Based on assurances that those states will impose an appropriately strict regulatory system, the Department deferred its right to challenge their legalization laws. But if any of the stated harms do materialize—either despite a strict regulatory scheme or because of the lack of one—federal prosecutors will act aggressively to bring individual prosecutions focused on federal enforcement priorities and the Department may challenge the regulatory scheme themselves in these states.
Founder / Managing Director
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