Between the Lines Blog

The Benefit of Achieving Tier III Classification for Marijuana and Cannabis Related Businesses
Category: Banking & Finance, Business
In 2020 the legal segment of the marijuana industry exceeded $10 billion dollars in the United States with California alone generating $3.1 billion in sales in 2019, and Colorado in a close second at $1.6 billion. With the solidified foothold the industry has gained in the marketplace and the sheer…
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The High Points: SARs and the Three Tiered Framework for MRBs
Category: Banking & Finance, Coronavirus (COVID-19)
As green states continue to grow, intentional or unintentional exposure to Marijuana Related Business (“MRB”) customers for financial institutions and broker-dealers is an inevitability. Whether your business has decided to actively shoulder the risk of allowing MRB customers in pursuit of the…
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Accuracy Counts: Filing Complete and Accurate SARs and Program Specific Red Flags Related to Covid-19 Criminal or Fraudulent Activity
Category: Banking & Finance, Coronavirus (COVID-19)
On September 29, 2020, at the 19th Annual AML & Anti-Financial Crime Conference, Financial Crimes Enforcement Network (“FinCEN”) Director Kenneth Blanco reported over 91,000 suspicious activity reports (“SARs”) have been filed related to Covid-19 criminal and fraudulent activity. These 91,000…
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Bankruptcy Courts are Easing Traditionally Rigid Lease Payment Requirements for Commercial Tenants In COVID-Related Filings
Category: Banking & Finance, Bankruptcy, Restructuring & Creditor-Debtor Rights, Business, Coronavirus (COVID-19), Litigation
Bankruptcy courts in multiple jurisdictions have granted tenant-friendly relief to companies that have filed for Chapter 11 bankruptcy in recent months. While the Bankruptcy Code typically requires timely performance of lease obligations under 11 U.S.C. § 365, bankruptcy courts have employed…
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The SBA Is Accepting New CARES Act Applications; Can Businesses Apply For More Than One Loan?
Category: Banking & Finance, Business, Coronavirus (COVID-19)
The President signed the Paycheck Protection Program and Health Care Enhancement Act into law on April 24, 2020, injecting an additional $484 billion in aid to supplement the SBA business loan programs created under the CARES Act. In particular, the new Act dedicated the following SBA funds: An…
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