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Corporate One’s policy on processing marijuana-related business transactions

As you may be aware, the Controlled Substances Act (CSA) makes it illegal under federal law to manufacture, distribute, or dispense marijuana. While certain states have legalized marijuana, which has spurred economic growth in this sector of business, federal law has yet to change. As such, Corporate One is clarifying its policy regarding prohibiting the processing of transactions related to certain marijuana-related businesses (MRBs).

Our policy restriction applies to all transactions processed by Corporate One that are conducted by, or on behalf of a Tier I MRB (definition below), regardless of whether the MRB is a member credit union’s member or not. The decision to refuse or reject a transaction we deem to be MRB related is up to the sole discretion of Corporate One in accordance with our policy.

Should you have any questions, please contact Member Experience at 866/MyCorp1. To learn more on this topic, you may review FinCEN’s guidance on BSA Expectations Regarding Marijuana-Related Businesses.

What is a Tier I MRB?

Any business that manufactures, distributes, or dispenses marijuana and/or THC or CBD products. These are entities that physically “touch” marijuana and/or these products. Examples of Tier I-related activities include:

  • Planting
  • Cultivation
  • Harvesting
  • Processing or Testing Facilities
  • Medical Dispensaries
  • Recreational Retail
  • Retail Delivery and Transporting
  • Packaging
  • Wholesaling
  • Cannabis Seeds
  • Cannabidiol
  • Infused Products
  • Industrial Hemp

A Tier I MRB may also be a potential shell company having the same address as an MRB.

What isn’t a Tier I MRB?

Entities that do not directly manufacture, distribute, or dispense marijuana and/or THC or CBD products, but may provide products and services to Tier I MRBs and the marijuana industry in general. These are known as “ancillary” or “indirect” MRBs. Examples of products and services offered include:

  • Hydroponic Supplies
  • Payment Processors
  • Packaging Supplies
  • Advertising and Public Relations
  • Licensing Consulting
  • Training and Education
  • Industry Associations
  • Marijuana Software
  • Professional Services Firms
    (e.g. attorneys, accountants, registered agents)
  • Commercial Property Owners