Four federal agencies (the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, and the Office of the Comptroller of the Currency) and the Conference of State Bank Supervisors issued a joint statement about the requirements for providing financial services to hemp-related businesses under the Bank Secrecy Act (BSA) and its implementing regulations. The guidance provides that financial institutions are not required to file suspicious activity reports (SARs) based solely on the fact that a business grows or produces hemp because hemp is no longer a Schedule I controlled substance under the Controlled Substances Act. Financial institutions are only required to file SARs if otherwise warranted by suspicious activity, and financial institutions are expected to have a BSA/AML compliance program in place for these businesses and must comply with other regulatory requirements for customer identification and verification, beneficial ownership, etc.
