certain positions requiring more frequent recertifications. We’re trained to know what to look for when an investigation is triggered, what questions to ask in regards to the activity in general, and how to determine if we’re seeing a change in expected business operations and why that might be occurring. Your banker is your best line of defense when it comes to ongoing banking access. They serve as your advocate and partner both internally for the financial institution and externally as you’re looking to grow and expand your business.
Ultimately the creation of FinCEN, the Bank Secrecy Act, and the subsequent amendments passed under the U.S. Patriot Act works to hold financial institutions accountable to ensure they’re doing everything in their power to safeguard the financial system and ensure they’re not knowingly facilitating terrorist financing, money laundering, and other illicit activity. The sweeping legalization of hemp under the 2018 U.S. Farm Bill created a new opportunity for financial access to companies engaged in the industry, but those of us who were trying to open the doors for hemp banking were faced with the challenge of a fairly unknown industry. There wasn’t transparency in financial operations that we could easily reference and there wasn’t even a basic level of understanding among corporate risk teams on the key difference between hemp and marijuana so the issue of how best to monitor the activity for the space became paramount in developing hemp programs.
Before I began working exclusively with the hemp industry in late 2018 I had managed two AML/BSA investigations for singular transactions but by the end of 2019 I had been involved in more than 50 individual investigations onhundreds of transactions related to what was typically normal transactional activity in the hemp space. I realized that we were dealing with an industry, that though it had been around for decades, it was not openly banked and the Federal classification for hemp before the 2018 Farm Bill was passed left the majority of financial