Financial Institution Risk Rating by Sector Based on Cole Memo
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Level: beginner
In the US, many financial institutions use the Cole Memo to advise their understanding of the government’s risk tolerance for cannabis customers. As part of the risk-based approach, the BSA officer should be able to identify how the Cole Memo Priorities map to the risks the financial institution is managing. This mapping demonstrates how a financial institution prioritizes its resources to manage the risk cannabis operators may expose them to based on the Cole Memo. This is a sample mapping of Cole Memo priorities to ACCCE’s five high-risk areas in the commercial cannabis industry by sector.
This resource is intended for:
- Cannabis Banking BSA, Compliance, or Risk Officers
- Professional Service Providers
- Banking Regulators