The Federal Reserve has named marijuana-related businesses as its example of a higher-risk bank customer. In a proposed guide for community banks published Sept. 15, the Fed says banks serving those clients may need stronger anti-money-laundering tools than the basic systems most small banks run. Comments are due Nov. 16.
What The Fed Actually Proposed
The document is the Proposed Third-Party Risk Management Guide for Traditional Community Banking Organizations (Docket No. OP-1880). It covers Fed-supervised banks with less than $30 billion in assets that focus on their local communities. That is the tier of bank most likely to hold a dispensary's operating account. It works alongside broader third-party risk guidance proposed jointly by the Fed, FDIC, OCC and NCUA.
The cannabis reference sits in a section on Bank Secrecy Act/anti-money-laundering (BSA/AML) software vendors. The Fed says basic tools will be enough for most community banks, but where clients present higher risk, citing marijuana-related businesses, "tools with more advanced capabilities may be appropriate."
The guide is not a rule. It creates no new requirement, and the Fed says ignoring it will not by itself trigger supervisory criticism. A footnote adds that examiners can still act on unsafe practices that come from weak third-party oversight.
Why It Matters For Your Bank Account
Banking access is already thin. A Government Accountability Office report released Sept. 8 found that about 1,000 banks and credit unions filed cannabis-related suspicious activity reports in 2024, roughly 11% of the nation's approximately 9,000 insured institutions. GAO noted some of those filings may involve one-off transactions rather than ongoing customer relationships.
The same report identified BSA compliance cost as a key reason banks decline cannabis clients. Some licensed operators pay more than $100,000 a year in fees just to keep a basic business account, according to the report.
Here is the tradeoff. Upgraded monitoring platforms cost money, and banks that buy them to serve cannabis clients will likely look to recover that cost through account fees. On the other hand, the Fed is treating cannabis banking as a risk to manage, not a line of business to avoid. That matches what regulators told GAO: they neither encourage nor discourage banks from serving the industry.
Notably, the guide still uses the term "marijuana-related businesses" without distinction, months after state-regulated medical marijuana moved to Schedule III. Rescheduling has not changed how bank supervisors frame the risk.
What Changes On The Front Line
The guide tells banks to track false positives, watch for unusual shifts in alert volume and secure contract rights to tune detection thresholds. For a dispensary, sharper monitoring means deposit patterns get more scrutiny. That puts finance leads, general managers and anyone who handles cash deposits closest to the impact.
Reconcile daily. Match every deposit to POS and seed-to-sale records so the numbers the bank sees line up with the numbers regulators see.
Ask your bank directly. Find out whether it is changing AML vendors or monitoring rules and what documentation it will request.
Train cash handlers on structuring. Splitting deposits to stay under the $10,000 currency transaction report threshold is a federal crime, even when the cash is legitimate.
Document predictable spikes. Holiday weekends, 4/20 and new store openings should have a written explanation on file before the bank asks.
Weigh in. Operators and their banks can comment through the Fed's proposals page under Docket OP-1880 through Nov. 16.
Frequently Asked Questions
Does this require banks to drop cannabis clients? No. The guide is nonbinding and says nothing about restricting service. It suggests banks with higher-risk clients consider more capable monitoring tools.
Which banks does it cover? Federal Reserve-supervised banking organizations with less than $30 billion in assets that focus on local communities. Banks with complex fintech partnership models are excluded.
Will my banking fees go up? The guide does not address fees. Given that GAO identified compliance cost as a primary barrier, operators should ask their banks whether planned monitoring upgrades will change account pricing.
The open question is whether the final guide keeps cannabis as its lone named example of a higher-risk client. The comment period is the industry's chance to shape that language before it hardens into what examiners expect.