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-3531-462496Marijuana Banking QuestionnairePlease note that this questionnaire has been developed to assist you in performing additional due diligence once you have identified a marijuana-related business through your CIP and CDD processes. This questionnaire should be used in conjunction with your CDD questionnaire or workflow and is not intended to be used solely on its own as your CDD questionnaire or workflow should capture information about anticipated account/transaction activity and other aspects of the customer relationship. Customer Name:Date of MRB Questionnaire Completion:Interviewer Initials:Please select licensing and registration type:? Grower? Processor? Distributor? OtherPlease provide a brief description:________________________________________Critical ContactsPlease list the name(s) and contact information for the individuals who have primary ownership and oversight of the business’s operations.NameAddressTelephone NumberEmail AddressAre any of the above-listed contacts, or beneficial owners of this business, also associated with another marijuana-related business? Please provide details.Operational DetailsState(s) of Registration and/or LicensingDo you work with the State’s LCB investigator other representative from the State’s regulatory body that oversees and enforces cannabis activity?States of OperationPlease include all states in which you grow, process or distribute marijuana-related productsDo you have any foreign (i.e. non-U.S.) operations?Do you conduct business internationally?If you conduct business internationally, please provide a description of the types of transactions conducted internationally and the countries with which the transactions are conducted.Product(s) Manufactured, Processed or DistributedTypes of Customers ServedContracts with Armored Car Services to Transport CashDoes the business directly transport cash to the Federal Reserve or will it be transacted through the bank?Do you utilize an accounting system?Do you handle your accounting in-house or utilize an external accountant/firm? If you utilize an external accountant/firm, please provide the accountant’s and/or firm’s name.Do you only receive cash payments or are you able to receive electronic payments?If you only receive cash payments and fund your operations with cash, please describe your current cash management practices (e.g. storage, access, etc.)?If you are able to receive electronic payments, what platform do you use to do so?How many employees do you currently have?Do you pay your employees in cash?If you pay your employees through ACH, what payroll processing system do you use?Cole Memo PrioritiesIs there any indication that the business is violating any of the following Cole Memo Priorities?PriorityYESNOPreventing the distribution of marijuana to minors??Preventing revenue from the sale of marijuana from going to criminal enterprises, gangs and cartels??Preventing the diversion of marijuana from states where it is legal under state law in some form to other states??Preventing state-authorized marijuana activity from being used as a cover or pretext for the trafficking of other illegal drugs or illegal activity??Preventing violence and the use of firearms in the cultivation and distribution of marijuana??Preventing drugged driving and the exacerbation of other adverse public health consequences associated with marijuana use??Preventing the growing of marijuana on public lands and the attendant public safety and environmental dangers posed by marijuana production on public land??Preventing marijuana possession or use on federal property??FinCEN Red FlagsIs there any indication of the following:Red FlagYESNOBusiness receives substantially more revenue than may be reasonably be expected given the relevant limitations imposed by the state(s) in which it operates???Business receives substantially more revenue than its local competitors or than might be expected given population demographics???Business deposits more cash than is commensurate with the amount of marijuana-related revenue it is reporting for federal and state tax???Business has failed or has been unable to demonstrate that its revenue is derived exclusively from the sale of marijuana in compliance with state law, as opposed to revenue derived from the sale of other illicit drugs, the sale of marijuana not in compliance with state law, or other illegal activity???Business makes cash deposits or withdrawals over a short period of time that are excessive relative to local competitors or the expected activity of the business???Business engages in the rapid movement of funds, such as cash deposits followed by immediate cash withdrawals???Business engages in excessive commingling of funds with the personal account of the business owner(s) or manager(s) or with accounts of seemingly unrelated businesses???Business has filed or has been unable to demonstrate the legitimate source of significant outside investments???Business engages in international or interstate activity, including by receiving cash deposits from locations outside the state in which the business operates, making or receiving frequent or large interstate transfers, or otherwise transacting with persons or entities located in different states or countries???If a retail outlet: ONLY sells marijuana, marijuana infused products and marijuana paraphernalia???If a retail outlet: ONLY sells marijuana advertised for medical purpose if the retailer has a “medical marijuana endorsement?”??Document(s) Needed? Registration and/or Licensing Documentation? Articles of Incorporation? Secretary of State Registration? Anti-Money Laundering (AML) Program? Results of any inspections performed by the state? Financial statements and federal tax returns for the last year, and projections for the next 1-3 years? Business attestation (e.g. agreement with terms and conditions of account and fee schedule, statement that the business is not in violation of Cole Memo priorities or FinCEN guidelines notification of changes to operations, ownership, etc.). ................
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