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ACAMS moneylaundering.com 24th Annual International AML & Financial Crime Conference - Hollywood

C26 - Joint Solutions: A Multi-Pronged Approach to Banking Marijuana-Related Businesses

Apr 16, 2019 3:05pm ‐ Apr 16, 2019 4:20pm


• Analyzing relevant FinCEN guidance on banking MRBs to ensure risk models meet regulatory expectations and identify potential conflicts with applicable state laws

• Training front-line staff on typologies such as commingling of bankable and non-bankable proceeds in order to strengthen risk-based monitoring related to marijuana

• Formalizing periodic reviews of MRB policies and procedures to keep risk models current and reflect institutional risk appetite and recent regulatory or legal developments


  • Lauren A. Kohr, CAMS-FCI, Senior Vice President, Chief Risk Officer, Old Dominion National Bank


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