West Coast AML Services
Cannabis Banking
Compliance Specialists

West Coast AML Services is a Bank Secrecy Act/Anti-Money Laundering risk management consultancy committed to the safety, soundness, and reputational integrity of financial institutions banking state-legal marijuana-related businesses.

Our Services

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.





H.R.1595 – Secure and Fair Enforcement Banking Act of 2019

The BSA’s criminal penalties for failing to establish an AML program appropriately designed to guard against money laundering through financial institutions (31 U.S.C. Section 5322 and 31 C.F.R. Section 1010.840) are not altered by the proposed SAFE Banking Act.


Our team brings a wealth of knowledge and expertise to the table with varying backgrounds in Federal law enforcement, banking, compliance and certifications including: Anti-Money Laundering Specialist (CAMS), Fraud Examiner (CFE), Public Accountant (CPA), and Forensic Interviewer (CFI).

“If they have rigorous compliancy all I can really say is they are less likely to get our attention, but I can’t go out and tell banks if you have rigorous compliance, you have immunity.”

United States Attorney for the District of Colorado
October 2018

Risk Management

It is expected that the Department of Justice will continue to assess the quality and effectiveness of state and local regulatory and law enforcement environments when creating targeting priorities. Keep in mind, FinCEN's guidance clarifying BSA/AML expectations for financial institutions providing services to state-regulated MRBs does not alter any provision of the BSA. Further, the proposed SAFE Banking Act does not mitigate the risk that marijuana-related businesses deposit proceeds into financial institutions from the sale of marijuana accomplished in any manner outside of state licensing and regulatory requirements and Department of Justice marijuana-related conduct enforcement priorities.

United States Attorney
Central District of California

In states that have decriminalized marijuana, we have seen an influx of foreign money used to establish grow operations, with much of the marijuana being destined for out-of-state consumers.

United States Attorney
District of Oregon

The recent HIDTA Insight Report on marijuana production, distribution, and consumption in Oregon confirms what we already know—it is out of control. Overproduction is rampant and the illegal transport of product out of state—a violation of both state and federal law—continues unchecked.

United States Attorney
District of Massachusetts

We Anticipate focusing marijuana enforcement efforts on overproduction, targeted sales to minors and organized crime and interstate transportation of drug proceeds. To that end, federal investigators will continue to police the Commonwealth for incoming or outgoing shipments of cash as well as use of the federal banking system.

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.

Terry M. Neeley
Founder / Managing Director

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