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Comprehensive Cannabis Banking Program

Comprehensive Cannabis Banking Program

by | Oct 6, 2020 |

Financial institution boards of directors and executives can use this resource to assist them when considering cannabis banking, or expanding a cannabis banking program. This one-pager will help you identify material due diligence processes, internal controls, and best practices to check your cannabis banking program against.

This checklist is intended for:

  • Financial institution board members
  • Financial institution executives
  • Financial institution compliance and risk functions

Produced by Andy Montgomery for the “Cannabis Banking in the Boardroom: Risk Management” Webinar.

Control Maturity Framework

Control Maturity Framework

by | Jun 6, 2022 |

Level: Beginner

As part of the risk-based approach, the Risk Officer should be able to identify the control maturity expected by the company. A Control Maturity Framework allows the company to consider its control expectations against its inherent risk to determine the strength of its risk-based quality of controls, giving a more accurate residual risk. It also provides the context for prioritization and depth of management responses to third-party findings. Understanding the control maturity expectation allows the company to apply the proper level of control based on its size and maturity, enhances the residual risk analysis of the risk assessment, and provides context for prioritization and management responses to third-party findings.

For example, ACCCE describes an Incomplete Control Framework this way. The capabilities have been reviewed to manage the risk, but show areas needing improvement or have not been validated for effectiveness.
Minimum requirements:
• Documented management control structure identifying responsibility and ownership

 

This resource is intended for:

  • Cannabis Compliance Managers and Officers
  • Cannabis Risk Managers and Officers
  • Professional Service Providers
  • Regulators
Crisis Management Policy and Objective Template

Crisis Management Policy and Objective Template

by | Apr 22, 2022 |

Level: Intermediate

There may be an occasion when a commercial cannabis business faces a crisis, whether internal or external, and the business should be prepared to respond with a crisis management program to ensure public safety and business continuity. A crisis is an emergency or adverse act that threatens a commercial cannabis business’s facility, employees, customers, stakeholders, or the industry as a whole.

ACCCE and WJCousins and Associates, an ACCCE Thought Leader alliance member, developed this Crisis Management Policy and Objective Template to help you implement a Crisis Management Program that prepares the business for a potential crisis. This policy and objective template identifies the Company’s intended outcome for a crisis as well as the qualified employee to design and implement the program.

This resource is intended for:

  • Commercial Cannabis Businesses
  • Risk and Compliance Officers
Crisis Management Program

Crisis Management Program

by | Jun 11, 2022 |

Level: Expert

There may be an occasion when a commercial cannabis business faces a crisis, whether internal or external. The business should be prepared to respond with a crisis management program to ensure public safety and business continuity. A crisis is an emergency or adverse act threatening a commercial cannabis business’s facility, employees, customers, stakeholders, or the industry.

ACCCE and WJCousins and Associates, an ACCCE Thought Leader alliance member, developed this Crisis Management Program to help you implement a Crisis Management Program that prepares the business for many potential crises such as fire, Workplace Violence, and Theft and Fraud.

ACCCE Members can download a sample Crisis Management Policy and Objective for Free: https://accce.org/product/crisis-management-policy-and-objective-template/

This resource is intended for:

  • Commercial Cannabis Businesses
  • Risk and Compliance Officers
De-Risking the Supply Chain

De-Risking the Supply Chain

by | Jun 18, 2021 |

Cannabis risk officers, save your business time and money by understanding the highest risk issues that the cannabis product supply chain exposes you to, and obtaining answers from our expert panelist Elise Serbaroli on how to manage those risks efficiently and effectively.

The licensed cannabis product supply chain is built to ensure handoff of the cannabis product through multiple license types before it is sold to the consumer to better manage risks to public health, public safety, and taxation. While this methodology has benefits, it also increases the complexity of managing your supply chain risks. Managing complex supply chains requires an understanding of the risks you are exposed to, identifying those risks in your supply chain, implementing controls to manage risks once identified, and being able to work with your supply chain to manage risk together.

Elise will discuss common high-risk issues, best practices in managing your risk, and how to explain these practices to vendors above and below you in the supply chain. She will link the challenges faced by the cannabis industry in managing supply chain risk, and how other highly regulated industries have solved for similar risks. Elise will also discuss how the right technology solution can help manage the high-risk issues identified in the cannabis product supply chain. Disruptions with single buyers or sellers, complex cross jurisdictional compliance requirements, and exposure to recalling cannabis product are just a few common high-risk issues that a cannabis risk officer must manage. Effective controls to manage your supply chain include, but are not limited to, analysis, forecasting, and oversight of resource planning, inventory tracking, testing, and contract management. Establishing your controls by identifying common high-risk issues will keep the overhead cost reasonable and reduce the impact and frequency of supply chain problems, but the most cost-effective way to manage supply chain risk is to work with your supply chain vendors both above and below you.

This is an ACCCE On Demand Webinar, available for immediate viewing.

Continuing Education: .5

Financial Institution Cash Deposit Guidance

Financial Institution Cash Deposit Guidance

by | Jul 13, 2020 |

Financial institution risk and compliance executives can use this reference to guide the conversation on whether to allow cash to be deposited in your branches from commercial cannabis businesses.

This resource is intended for:

  • Financial institution compliance and risk functions

Produced by Chris Gunias for the “5 High Risk Areas of Cannabis Banking Webinar”, this reference document runs through the risks a financial institution should consider in their due diligence and enhanced due diligence for allowing a commercial cannabis business to deposit cash at a branch.

Financial Institution Due Diligence Checklist

Financial Institution Due Diligence Checklist

by | Jul 13, 2020 |

Financial institution AML and BSA staff can use this reference to guide the conversation on what to review for cannabis banking due diligence.

This resource is intended for:

  • Financial institution AML/BSA function

Produced by Cathy Scharf for the “5 High-Risk Areas of Cannabis Banking” webinar, this checklist runs through the material differences a financial institution should consider in their due diligence and enhanced due diligence.

Financial Institution Risk Rating by Sector Based on Cole Memo

Financial Institution Risk Rating by Sector Based on Cole Memo

by | Jun 6, 2022 |

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
Four Simple Steps to Managing Risk & Compliance

Four Simple Steps to Managing Risk & Compliance

by | Mar 12, 2021 |

Cannabis risk officers, obtain the trusted answers you need to meet your business objectives and reduce risk with this printable resource that highlights four steps for identifying and managing risk effectively. This resource will help you learn how to identify your highest inherent risks and implement a mitigation plan that prioritizes your highest residual risks and holds risk owners accountable.

This fact sheet is intended for:

  • Commercial cannabis risk officers
  • Commercial cannabis compliance officers

Produced by Andrew Cole for the ACCCE webinar Compliance Management Best Practices: Putting the Risk Assessment to Work for You

Inherent Risks Associated with Brand Companies

Inherent Risks Associated with Brand Companies

by | Oct 14, 2020 |

Financial institution compliance and risk personnel can use this resource to assist them when conducting due diligence on commercial cannabis business customers. This infographic will help you understand how a brand company may work with your commercial cannabis customer, and what inherent risks should be considered when evaluating that relationship.

This infographic is intended for:

  • Compliance Managers
  • Compliance Analysts
  • BSA/AML Officers
  • AML Analysts
  • Risk Managers
  • Risk Analysts

Produced by Carole McCormick for the “Cannabis Banking Due Diligence – Deep Dive” Webinar.

 

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