Financial Institution Risk Rating by Sector Based on Cole Memo

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