Under the Microscope with Jenny

Ep. 50: Cannabis & Banking: Bridging the Gap Between Operators & Institutions


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๐ŸŽ™In this episode of Under the Microscope with Jenny, host Jenny Germano, sits down with Chris Van Dyke, Partner at Cogent Law, to break down one of the most complex and often misunderstood areas of the cannabis industry: banking. Chris brings a rare, dual-perspective background, having helped launch one of the early cannabis banking programs and serving as a state regulator during the rollout of the 2014 FinCEN guidance. Today, he advises banks and credit unions on how to safely and effectively serve cannabis-related businesses (CRBโ€™s). Together, Jenny and Chris unpack the fundamentals defining key terms like BSA (Bank Secrecy Act), and SARs (Suspicious Activity Reports) while exploring the shared compliance burden between operators and financial institutions. They walk through the real risks banks face, particularly around BSA/AML compliance, and why many institutions remain cautious despite growing demand.

The conversation also addresses common misconceptions about cannabis banking, the evolving regulatory landscape, and why financial institutions are increasingly entering the space from fee-based revenue opportunities to portfolio diversification and long-term customer loyalty. Jenny and Chris dive into practical guidance for operators, including how to vet a cannabis-friendly bank, what to expect during onboarding and due diligence, and how to position your business as a low-risk, transparent customer. This episode is a must listen for operators looking to secure and maintain strong banking relationships, reduce compliance risk, and better understand how financial institutions are navigating the cannabis industry behind the scenes.

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๐ŸŒฟ๐—ข๐˜‚๐—ฟ ๐—›๐—ผ๐˜€๐˜: Jenny Germano, Founder of ICS Consulting

๐ŸŒŽ ๐—œ๐—–๐—ฆ ๐—–๐—ผ๐—ป๐˜€๐˜‚๐—น๐˜๐—ถ๐—ป๐—ด: https://www.icsconsultingservice.com


๐ŸŒฟ๐—ข๐˜‚๐—ฟ ๐—š๐˜‚๐—ฒ๐˜€๐˜: ย  Chris Van Dyke, Partner at Cogent Law
๐ŸŒŽ๐—ช๐—ฒ๐—ฏ๐˜€๐—ถ๐˜๐—ฒ: https://cogentlaw.com

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โฐ๐—ง๐—ถ๐—บ๐—ฒ๐˜€๐˜๐—ฎ๐—บ๐—ฝ๐˜€โฐ

01:05 Chris Intro & Background

04:53 Defining CRBโ€™s & Indirect CRBโ€™s
07:50 Shared Compliance Burdens
13:24 BSA & SAR Definitionsย 
15:06 Misconceptions about Cannabis Banking & Progress
20:23 Stigma Shifts & Rescheduling
23:11 Three Circles of Risk
25:41 FinCEN Guidance
26:40 Why Banks Bank Cannabis
29:20 Hemp Banking Uncertainty
32:32 Vetting Your Cannabis Bank
36:24 CRB Onboarding & Due Diligence
37:55 Deposits, Lending & Underwriting
40:13 MSO Versus Small Operator Risk
42:25 Being a Transparent CRB Customer
46:49 Avoid Banking Relationship Pitfalls
48:38 Final Tips & Wrap-Up

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๐—Ÿ๐—ฒ๐—ด๐—ฎ๐—น ๐——๐—ถ๐˜€๐—ฐ๐—น๐—ฎ๐—ถ๐—บ๐—ฒ๐—ฟ: The content shared on this channel - including all videos, podcasts, interviews, and discussions is provided for educational and informational purposes only. It is not intended as legal, compliance, or business consulting advice, and should not be relied upon as such. Laws and regulations surrounding cannabis and related industries vary by jurisdiction and are subject to change. Always consult with a qualified attorney or licensed professional before making decisions that could have legal or regulatory consequences for your business. Listening to or viewing this content does not create a client relationship between you and ICS Consulting, Under the Microscope with Jenny, Jenny Germano, or any of the podcastโ€™s guests. Any opinions expressed are those of the individual speakers and do not necessarily reflect the views of ICS Consulting or its affiliates.

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Under the Microscope with JennyBy Jenny Germano