1. Crash Course:
Banking, Payment Processing &
Cash Management
Lance Ott
Founder/CEO
Guardian Data Systems

2. Background and Challenges
 Banking Access
 Banking Law
 National Banks
 Local Banks

3. Common Questions
Why are debit/credit cards restricted at
cannabis businesses?
What do banks do when they suspect
personal or business accounts are
being used for a cannabis business?
Banking Issues

4. Recent Developments
February 14th – FinCEN issues new banking guidance
 The guidance:
 Clarifies how they can provide services to
marijuana-related businesses.
 Outlines due diligence practices financial
institutions should follow to avoid
prosecution
 Pending Legislation

5. Financial Institution Responsibilites
SAR – definition
Cannabis Limited SAR
Cannabis Priority SAR
Cannabis Termination SAR
What to do now

6. Red Flags and Disturbing Trends
 Red Flags For Financial
Institutions
 Offshore Accounts
 Miscoding of Applications
 Risks – TMF/Match

7. What Are The Risks?
 Holding or loss of funds
 Match List (TMF)
 Inability to open a future
Merchant Account/DDA

8. Financial Industry Response
 Will the guidance be enough?
 Cannabis still illegal under federal law
 Banking Organizations’ Response
 Serious Public Safety Issue
 Oversight / Costs / Fees
 FinCEN – Over 300 banks supporting
industry.

9. Current Options
 CASH is still king – MASSIVE public safety issue
continues.
 Credit & Debit Cards - NO
 ATMs - NO
 Cashless ATMs – NO
 Coupons, Vouchers, Checking account schemes - NO
 Kiosks
 Closed Loop

10. Continue To Build Acceptance
 Increased Political Pressure
 Oregon Banking Bill – HB 4094
 Marijuana Business Banking Act of 2015
 The Compassionate Access, Research
Expansion & Respect States’ Act of 2015
(CARERS ACT)

11. Work With A Qualified Professional
 Work with a trusted advisor
 Perform your own due diligence
 Experience in the cannabis industry?
 Internal compliance program/policies
procedures. Comply with laws/rules/regs.

12. Thank You
Lance Ott, ETA CPP
Principal
Guardian Data Systems
Lance@GuardianDataSystems.com
888-900-0420
www.GuardianDataSystems.com
Twitter - @GuardianDataSys

13. Lance Ott
Guardian Data Systems
Founder/CEO
Crash Course: Banking,
Payment Processing &
Cash Management