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FinCEN Guidance: How To Hemp

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On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) released guidance (the “Guidance”) on the Bank Secrecy Act (BSA) and anti-money laundering (AML) obligations and considerations surrounding hemp-related customers. These customers include hemp growers, and processors and manufacturers that purchase hemp from such growers. The Guidance supplements a December 2019 interagency statement, summarized in our prior Client Alert, and outlines how financial institutions can comply with their BSA/AML requirements when providing services to hemp-related clients.

Generally, hemp-related businesses are subject to the same requirements as any other customer. However, the Guidance emphasizes that in order to adequately assess risk, financial institutions may need to fully understand the regulatory context in which these customers operate.

Background

The Agriculture Improvement Act of 2018 (the “2018 Farm Bill”) removed hemp from the definition of marijuana in the Controlled Substances Act, thereby declassifying hemp as a Schedule I narcotic. The 2018 Farm Bill also legalized hemp production under certain conditions and instructed the United States Department of Agriculture (USDA) to establish the necessary regulatory framework. In October 2019, the USDA issued an interim final rule, pursuant to which state and tribal governments may: (1) submit plans to the USDA for regulating hemp within their jurisdictions; (2) rely on the USDA’s federal licensing plan; or (3) prohibit hemp entirely within their jurisdictions.

BSA/AML Program Expectations

As with any customer, financial institutions must apply initial and ongoing customer due diligence procedures (customer identification and verification (CIP), beneficial ownership information for legal entity customers, and risk-based customer due diligence/enhanced due diligence (CDD/EDD)) to hemp-related businesses. Suspicious Activity Reports and Currency Transaction Reports must be filed upon discovering suspicious activity and currency transactions above $10,000 in aggregate on a single business day, respectively. In addition, FinCEN’s guidance on marijuana-related businesses remains valid, and it may be implicated by transactions that mingle hemp and marijuana funds.

For hemp growers, compliance with state, tribal government, or USDA licensing requirements may be verified by obtaining either: (1) a copy of the license, or (2) a written attestation from the grower of valid licensure. As for additional due diligence, FinCEN encourages a risk-based approach. Financial institutions may consider requesting crop inspections, testing reports, license renewal information, and copies of correspondence with regulatory agencies.

Conclusion

The Guidance in intended to improve access to financial services for hemp-related businesses, but FinCEN stresses that financial institutions must understand the nature and purpose of a customer relationship to recognize, monitor, and mitigate the related risks. Hemp regulation in the United States is complex, and varies between states, and between the state, tribal government, and federal levels. License requirements may hinge on terms such as “cultivate” and “process,” which may be defined differently between jurisdictions. Hemp-related activities within one state may be regulated by different agencies. Moreover, as the hemp industry expands in the United States, rules and guidance are subject to change frequently. Financial institutions seeking to service hemp-related customers should thoroughly understand the hemp regulatory regime, as well as their hemp customers’ business activities.

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Source: https://cannabislaw.report/fincen-guidance-how-to-hemp/

Cannabis

Shelf-life stability: Here’s what cannabis-infused product makers need to know

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(This is an abridged version of a story that appears in the August issue of Marijuana Business Magazine.)

Shelf-life stability is no less important to cannabis business owners than it is with traditional food products or dietary supplements.

It’s important for manufacturers of infused cannabis goods such as candies, beverages and creams to understand how their products’ makeup can change over time.

Armed with that knowledge, it’s possible to determine how long those products will last on store shelves and in consumers’ homes.



“Shelf-life stability in the world of cannabis-infused edibles is essentially no different than it is in the world of regular food products or dietary supplements,” Drew Hathaway, senior scientist at Colorado-based Stillwater Brands, told Marijuana Business Magazine.

“The three key pillars of shelf-life stability for any industry should be understanding how your product’s physical, chemical and microbial stability can potentially change over the full duration of the product’s shelf life.”

Experts in the field contacted by Marijuana Business Magazine shared their insights on:

Source: https://mjbizdaily.com/how-to-improve-shelf-life-for-cannabis-infused-products/

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Does Charlie Puth Smoke Weed?

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At 28-years-old, Charlie Puth has already made a successful career that includes Grammy and Golden Globe nominations, with each new record exposing new layers of his talent, all resulting in music that bears his personal stamp.

This week, it was revealed that Puth is sitting on an unreleased collab with fellow singer and songwriter Zayn Malik.

No word if the song will ever be released, but what we really want to know is: Does Puth smoke weed?

Puth has spoken up several times about his social anxiety, his struggles with fame, how he has a hard time dating, and how all of that has influenced his life and music. Still, he’s very tight lipped about his drug use.

RELATED: Does Harry Styles Smoke Weed?

In a 2018 interview with Billboard magazine, he explained that his rise to fame was fast and contributed to him overusing marijuana while hanging out with Wiz Khalifa. “He was like, ‘Fool, put this in your tea!’ I was like, ‘Why do I feel relaxed all of a sudden?’ It was liquid THC!” He said that for a time he was out smoking some rappers.

Everything You Need To Know About Cannabis And Hemorrhoids
Photo by Cappi Thompson/Getty Images

Puth reminisced about eating “like a pound of marijuana cookies” and having a six-hour freakout.

“I thought I had to party and date a lot of girls and just go crazy,” he said. “I thought it was what was expected of me as a musician. My mom was the one who was like, ‘You’re losing touch with why you got here.’”

RELATED: Does Dakota Johnson Smoke Weed?

In that same interview he said that he now doesn’t smoke weed in order to preserve his falsetto. So, according to his statements over the years, Puth doesn’t seem to be too interested in weed, in whatever shape it comes.

Source: https://thefreshtoast.com/celebrity/does-charlie-puth-smoke-weed/#utm_source=rss&utm_medium=rss&utm_campaign=does-charlie-puth-smoke-weed?utm_medium=Feed&utm_source=Syndication

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How to make a cannabis-infused piña chillada

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Cannabis beverages are a growing trend, and it’s easy to understand why. From CBD-infused coffee to THC microdose sodas, there are seemingly endless flavors and styles that can be used to make stoney signature drinks in place of traditional cocktails. 

While no one is trying to take away our precious margaritas or frosé, reducing alcohol consumption in general is increasingly popular among people of all ages. With physical and mental well-being seen top priority, cannabis drinks can satisfy the thirst for delicious beverages that provide relaxation without hangovers or added calories.

Part of the fun of cocktails is the element of craft that goes into them. Of course, the many ready-to-drink cannabis beverages can be enjoyed on their own as an alternative to alcoholic tipples, but for those who crave the ritual of mixing something unique in their home bar — or for those who want to enjoy a complex drink that equal more than the sum of its parts — these recipes are for you. 

The concoctions below use a combination of pre-made infused beverages and tinctures. Any type of tincture, such as full-spectrum hemp, CBD or THC, will work, though we are partial to nano tinctures that are made specifically for beverages since they mix in easily and don’t change the flavor profile. 

How to make delicious cannabis-infused cocktails

Before you start mixing, there’s a few tried-and-true tips you should have at your disposal for the best canna-cocktail experience: 

  • After following a recipe, periodically taste and adjust the amounts of each ingredient to create your ideal balance.
  • Add your own flare: play around with garnishes to put a personalized stamp on homemade drinks. Try anything from cinnamon sticks to fresh figs. 

Why the piña chillada 

Tropical drinks always taste like vacation in a glass, and with a cannabis boost, they can also feel like vacation. This Pinna Chillada uses all-natural ingredients, featuring coconut milk instead of sweet and processed cream of coconut. 

Aside from being a healthier option, natural full-fat coconut milk can enhance the effects of cannabis. This is a very forgiving recipe that can be easily customized: adjust the amount of maple for desired sweetness and adjust water for desired consistency. If you don’t have frozen pineapple, use fresh or canned and use a few ice cubes instead of cold water. 

Gina Coleman/Weedmaps

Ingredients:

  • 2 oz coconut milk
  • ½ oz maple syrup
  • 2 oz pineapple juice
  • 4 oz frozen pineapple chunks
  • Splash of cold water 
  • Tincture of choice

Method:

  • Combine all ingredients in a blender and blend until smooth.

Products we mixed: Kickback Nano Tincture 

A 2 millimeter serving size of Kickback Nano Tincture contains 5 milligrams of CBD.

Available: Nationwide

Photos by Gina Coleman/Weedmaps

Source: https://weedmaps.com/news/2020/07/how-to-make-a-cannabis-infused-pina-chillada/

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