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Public companies both with and without privately-held subsidiaries, companies with hybrid corporate structures including less-than-wholly-owned interests in other operating entities (licensed and otherwise) as well as multi-state licensed operators present unique challenges in obtaining compliant, transparent, stable bank accounts.

Much of this is due to a prevailing policy among many cannabis-friendly financial institutions to limit accounts to those operating within their specific state or region. Some also have policies restricting welcoming public entities (either licensed or with an interest in licensees) as customers due to difficulties in conducting adequate due diligence and achieving adequate compliance with regard to invested capital and/or beneficial owners. Also public companies may implicate additional Federal compliance requirements and SEC scrutiny that banks, especially those relatively new to compliant cannabis banking, are reluctant to undertake at this time.

FINCANN has several financial institutions in its network that will compliantly and transparently provide banking to all such entities anywhere in the USA.

Since we are committed to building our bandwidth of cooperating compliant banks across the country to provide service to the entire industry by 3/Q 2018 at the latest, additional financial institutions are coming on board all the time.

By both regulation and written guidance (FinCen, Cole and Rohrbacher/Blumenauer) the banks are required by Federal and State examiners, as well as the US Depts of Justice and Treasury (FinCen) to undertake rigorous and effective measures to assure the following:

  • The beneficial owners and principals of the licensed MRB have clean records
  • The MRB is properly licensed and compliant with all reporting and operational requirements of their licensing authority
  • The MRB is operating in substantial compliance with Cole Memo priorities
  • Effective reporting and operational protocols and procedures are strictly adhered to prevent the co-mingling of any revenue or sale proceeds from other operations (legal or otherwise)
  • That plant-derived inventory is fully tracked and accounted for to prevent diversion

FINCANN assists both financial institutions and MRBs in establishing and auditing adequate, cost-effective compliance programs based upon business type. We can provide an inexpensive mobile compliance scoring app with predictive AI to monitor over 200 data points specific to state and business type so either you or the bank can both monitor and improve compliance on an ongoing basis.

It has become clear that a MRB’s long-term sustainability is directly proportional to the quality and transparency of its compliance and accountability and FINCANN is committed to helping you achieve this goal.

In applying for a compliant bank account, be prepared to undergo a 3-4 week rigorous process of due diligence and reporting, including a mandatory onsite compliance inspection of all licensed facilities. The process generally requires initial application, advisory and compliance fees and often a minimum advance (refundable) account deposit. There are also logistics costs associated with securely moving cash deposits. Ongoing account maintenance fees are usually a percentage of deposits (generally ranging from 0.25% - 2.5%) with a monthly minimum and maximum per account.

FINCANN as your advocate and expert guide to support you through the initial onboarding and due diligence phase to cost-effectively achieve your principal goal: stable, transparent, simplified banking. And we'll provide you the tools and guidance for long-term sustainability.

Once a compliant bank account is established, FINCANN can provide a variety of (now-compliant) electronic (cash-free) payment solutions, including MasterCard, Visa, American Express, Discover & JCB, as well as electronic ‘wallet’ programs and electronic check apps. We’ll work with you to implement the optimal package for your specific circumstances, especially since market pricing currently ranges from roughly 2.9% to 8.4% with 3-6 month rolling reserves of between 0% - 10%.