Financial Institution Risk Rating by Sector Based on Cole Memo
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