Banking in the Cannabis Industry

Suspicious Activity Report (SAR)

Disclaimer: The materials available at this web site are for informational purposes only and not for the purpose of providing legal advice. You should contact your attorney to obtain advice with respect to any particular issue or problem.

A SAR is a report that a financial institution is required to fill out if they believe one of the transactions within their institution is for any reason suspicious, and might signify money laundering, tax evasion, or other criminal activities.

As a result of the FinCEN Guidance of Feb. 2014, all financial institutions that deal with marijuana related businesses are required to file a marijuana specific SAR for all transactions of the marijuana related business.  This includes all transactions that would be considered perfectly legal under current state law.

See the full text of the FinCEN guidance here.

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