Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Most Recent Updates • Jeff Sessions o “Rescinded” the Cole Memo •
Cole Memo provided updated guidance to US Attorneys related to prosecuting marijuana crimes. • FinCEN then provided a path for Casino’s to do business with Marijuana Based Businesses (FIN-2014-G001)
o Calls federal law “Supreme law of the land”
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What to Do • Marijuana based businesses (if legal in your state) MUST be identified as a risk in your compliance program. • Based solely on Jeff Sessions’ comments, two choices: o Do nothing and risk a FinCEN fine; or o File a SAR
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BlueBird, CPAs
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