Tailored Education for Cannabis Banking
Tailored education allows you to quickly and affordably access the information and tools your teams need to implement or enhance your cannabis risk management practices.
ACCCE offers a range of specific cannabis banking training and workshop topics to fit your needs
Cannabis Banking Tailored Training
Elevate Your Cannabis Banking Program
ACCCE provides tailored training and workshops for financial institution directors, C-suite executives, and compliance/AML functions. Each program is uniquely designed specifically for your financial institution’s control environment and specific cannabis client risk profile. Facilitators are ACCCE staff who were financial institution compliance officers and subject-matter experts.
Adding Commercial Cannabis Businesses to Your Customer Base
Learn about the specific commercial cannabis businesses that fit your financial institution’s risk profile, create your initial risk assessment, and define your control road map. This workshop includes information on the following:
- Review of the sectors and subsectors of ancillary and commercial cannabis businesses
- Identify common inherent risks specific to money laundering, illicit cannabis market, compliance, supply chain, and operational risk areas
- Determine how your financial institution’s current procedures map to the five major risk areas for commercial cannabis businesses
- Common risk mitigation to implement based on the risk assessment
- How the financial institution could use this information to form a residual risk that the customer poses
- Provide sample documents such as:
- Inherent risk profile by commercial cannabis sector
- Risk assessment to provide to your commercial cannabis business customers
- Future state of cannabis banking controls based on the risk assessment
Cannabis Banking Due Diligence: Initial Onboarding of Commercial Cannabis Businesses
Understand the top risks affecting commercial cannabis businesses, the role of AML in setting up the cannabis banking program, and how to create the initial risk profile for commercial cannabis businesses. This workshop includes information on the following:
- Review of the five major risk areas unique to commercial cannabis businesses
- Evaluating the five major risk areas during cannabis banking initial onboarding and site visits
- Analysis of the financial institution’s control activities as they map to the five major risk area
- Applying the ACCCE Cannabis Risk Management Framework (CRMF) to the financial institution’s commercial cannabis customer risk assessment to enhance its customer risk profile
- Analyzing common risk mitigation to implement based on the financial institution’s risk assessment
- Provide sample documents such as:
- Inherent risk profile by commercial cannabis sector
- Risk assessment to provide to your commercial cannabis business customers
- The future state of cannabis banking controls based on the risk assessment
Cannabis Banking Due Diligence: Integration of AML Tools for Cannabis Business Due Diligence
Understand how to enhance your current AML tools to efficiently manage your cannabis banking clients. This workshop includes information on the following:
- Review of the five high-risk areas of commercial cannabis businesses
- Identification of how to manage the risks by risk drivers
- How the financial institution’s procedures map to the five major risk area drivers
- Integration of AML systems and processes into the management of commercial cannabis businesses
- AML scores
- AML profile scores
- AML alerts
- Integration of commercial cannabis business systems and processes into the management of commercial cannabis businesses
- Risk scores
- Risk profile scores
- Risk alerts
- How to monitor the customer over time by risk profile with risk-based controls
- A path to have the customer self-audit to provide unique oversight information to the financial institution
- Provide sample documents such as:
- Schedule of risk assessment based on customer risk profile
- Scorecard to integrate AML systems and processes, other risk scores and alerts, and ACCCE risk drivers to monitor for changes in the customer risk profile
- Commercial cannabis business self-audit schedule
Maturing Cannabis Banking Relationships
Align your cannabis customers with the financial institution’s AML priorities for risk oversight to set clear expectations for reporting, oversight, and risk management. Provide tools to help your cannabis customers deliver the needed information:
- Review of commercial cannabis enforcement actions in the US and Canada
- Identify how to create a roadmap to keep the commercial cannabis business’s risk function maturing to the financial institution’s needs
- Identify emerging cannabis risk management best practices
- Create a self-audit worksheet for your cannabis clients
- Provide sample documents such as:
- Future state of cannabis banking controls
- Commercial cannabis business self-audit worksheet
- Commercial cannabis business risk program
- Commercial cannabis business issue management work program
- Commercial cannabis business vendor management work program
- Commercial cannabis business ethics and whistleblowing work program
Effective Board and AML Committee Oversight of Cannabis Banking
Understand the key responsibilities of the board and AML committee, those areas that pose the greatest risks, and issues that should be escalated to the full board. This workshop includes information on the following:
- Review of the ACCCE Cannabis Risk Management Framework
- Review of commercial cannabis enforcement actions in the US
- How to create a roadmap to keep the commercial cannabis business’s risk function maturing at the financial institution’s needs, with specific focus on aligning to the DOJ guidance on Evaluation of Corporate Compliance Programs
- How to identify the target group of commercial cannabis businesses
- How to identify target risk mitigation activities
- How to make recommendations unique to the risks of the commercial cannabis customer
- Documenting follow up on the recommendations
- Provide sample documents such as:
- Lead cannabis director responsibilities
- Issues and concerns in cannabis banking
- 10 questions to challenge management on the cannabis banking program
- Self-review: cannabis banking program
- AML officer report to Risk Committee
Annual Training: Cannabis Banking
Tailored to your financial institution’s specific commercial cannabis business types and market area, this is continuing education for the day to day managers and applicable financial institution staff to stay up to date on red flags and emerging risks in the commercial cannabis industry. This training includes:
- Identify the major sectors and sub sectors of the commercial cannabis industry
- Review of the five high risk areas unique to the commercial cannabis industry
- Challenges identified by FinCEN and FinTRAC for cannabis banking
- Breakdown of major commercial cannabis enforcement actions from cannabis regulators in the US and Canada to identify emerging risks and changes
Best Practice Reviews
Enhance Your Program
ACCCE provides Best Practice Reviews for the overall cannabis banking program or targeted program elements. ACCCE prepares a proposed review scope and request letter that allows us to tailor the final report to your financial institution. ACCCE will also identify the examination manuals and other industry sources (FFIEC, FinCEN, DOJ) and the ACCCE Cannabis Risk Management Framework that we would use to guide the review. The resulting report will identify recommendations based on these documents and your institution’s identified control maturity framework. Here is a sample of the program elements we cover:
Onboarding
Review the institution’s practices to address risk before onboarding and the initial due diligence, including risk rating. Confirm the risks and mitigants specific to the financial institution are considered in its risk-based approach to reduce AML risk.
Governance
Enhanced due diligence
Unusual activity
MRB SARs
Contact Us
Contact us today to elevate your cannabis banking program with the Cannabis Risk Management Framework.