Preparing for 4/20: Specialty Banking & Cannabis Programs Unpacked
- Feb 19, 2024
- 3 min read
Updated: Aug 12
Last updated: July 27, 2026 | By: Peter Su and Kristin Parker
Key Summary
A sustainable cannabis banking program needs documented risk parameters, specialized due diligence, ongoing monitoring, clear escalation procedures, and tools that help the team maintain consistent oversight. These requirements matter throughout the year, not only around 4/20. RiskScout supports financial institutions that want to serve cannabis-related businesses while maintaining examiner-ready controls.
Join industry experts Peter Su and Kristin Parker as they dive into the dynamic realm of specialty banking, with a specific focus on cannabis and hemp. You’ll gain invaluable insights into the intricacies of specialty banking, from hiring specialized staff to setting realistic expectations and leveraging the right tools for success. Dive deep into the current landscape of cannabis banking, exploring detailed policies, procedures, and regulatory considerations to ensure compliance and mitigate risks effectively.
Join this session and learn:
How to unlock profits without headaches from specialty markets
Unique intricacies and pot holes for cannabis banking
How to operate a successful program with limited staff and resources
What a Year-Round Cannabis Banking Program Needs
A cannabis banking program should define how the institution selects, onboards, monitors, and reviews each relationship.
Program boundaries: Define which cannabis or hemp businesses the institution will consider.
Licensing and ownership: Establish the documentation required to verify the business, its owners, and applicable licenses.
Expected activity: Document expected deposits, payments, locations, products, and other activity relevant to monitoring.
Ongoing due diligence: Set review triggers and a consistent process for collecting updated information.
Escalation and reporting: Define how the institution investigates concerns, makes SAR decisions, and exits relationships when necessary.
Clear workflows help limited teams manage reviews without rebuilding the process for every customer or member. RiskScout brings due diligence, transaction monitoring, direct communication, case management, and reporting into one BSA/AML platform.
Frequently Asked Questions
Is cannabis banking compliance only an issue around 4/20?
No. A cannabis banking program requires year-round onboarding, due diligence, transaction monitoring, documentation, and reporting. The date can prompt a program review, but the underlying controls must operate throughout the year.
What federal guidance applies to marijuana-related business banking?
FinCEN's FIN-2014-G001 describes BSA expectations for financial institutions that provide services to marijuana-related businesses. Institutions must also consider applicable state requirements and their own risk-based policies.
What should cannabis customer due diligence include?
Due diligence should help the institution understand ownership, licensing, business activities, expected transactions, markets served, and changes in the relationship. The depth and frequency of review should reflect the risks of the individual customer.
How are Marijuana Limited, Priority, and Termination SARs different?
FinCEN's guidance describes different filing approaches based on the institution's assessment of the relationship and identified concerns. RiskScout's Cannabis SARs Made Simple downloadable provides ready-to-use templates for these filing types.
Meet the Presenters:
Peter Su, Director of Specialty Banking at First Central Savings Bank
Peter is a banking executive with 20+ years of experience across the banking and financial services spectrum. He has personally spearheaded 2 cannabis banking programs as team leader at commercial banks and is in the process of building out his 3rd program. He has also worked as a consultant to dozens of financial institutions across the country banking cannabis.
An active member of the cannabis industry, Peter is currently on the executive board of the Asian Cannabis Roundtable, serving as treasurer, and an advisory council member for the Minority Cannabis Academy. Peter is a frequently guest lecturer at institutes of higher learning, like Rutgers, Hofstra Law, and others. Additionally, he writes about the cannabis industry for Rolling Stone on the Rolling Stone Cannabis Culture Council.
Previously, he also held a position as an advisory panel board member for Pace University's Lubin School of Business as well as served as a member of the Banking & Financial Services Committee for the National Cannabis Industry Association. And he is a veteran of the United States Army.
Kristin Parker, SVP of Customer Success
Prior to joining RiskScout, Kristin worked on both fraud and BSA teams, where she successfully created and implemented BSA monitoring programs at community financial institutions for varying higher risk industries like hemp, MSBs, ATMs, cannabis, and more. She was also recently selected by peers as PBC's Compliance Person of the year.
