Understand the Regulatory Context
A board does not need to become the day-to-day cannabis banking operations team. But before approving a cannabis banking program, board members do need to understand enough to ask the right questions and document a thoughtful decision.
First, the board should understand the legal and regulatory backdrop. Cannabis remains an area where federal and state frameworks continue to evolve. Federal rulemaking activity in April 2026 concerning proposed marijuana rescheduling illustrates why leadership teams should not treat the issue as static [3]. Regulatory change does not eliminate the need for clear governance.
Know Exactly What the Institution Is Approving
Second, the board should understand what the institution is approving. “Cannabis banking” is not one product. A program may include deposit accounts, cash services, ACH, wires, treasury management, lending, armored carrier coordination, indirect customer exposure, or service-provider relationships. Each product adds different operational and compliance considerations.
Third, the board should know the institution’s risk appetite. What types of cannabis-related businesses will be considered? Direct marijuana licensees? Indirect businesses? Hemp businesses? Landlords? Professional service providers? Will the institution lend, or only accept deposits? What level of cash activity is acceptable? These decisions should be made deliberately, not account by account under pressure.
Resource the Controls and Expect Useful Reporting
FinCEN’s guidance emphasizes customer due diligence, state license verification, expected activity, adverse media monitoring, suspicious activity monitoring, and periodic refresh of customer information [1]. The board should not manage those tasks, but it should understand that they require people, systems, training, and budget.
Finally, the board should expect reporting. Good reporting does not have to be complicated. It should help directors see customer counts, risk levels, exceptions, SAR trends, audit findings, staffing needs, vendor issues, and examiner feedback. The FFIEC BSA/AML Examination Manual reinforces the importance of a risk-based compliance program and risk assessment structure [2].
A cannabis banking program should not be approved with a vague “yes.” It should be approved with a documented strategy, a defined scope, assigned accountability, and ongoing board oversight. That is how a board moves from curiosity to governance.
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Sources
1. [FinCEN, BSA Expectations Regarding Marijuana-Related Businesses (FIN-2014-G001)](https://www.fincen.gov/resources/statutes-regulations/guidance/bsa-expectations-regarding-marijuana-related-businesses)
2. [FFIEC BSA/AML Examination Manual](https://bsaaml.ffiec.gov/manual)
3. [Federal Register, Schedules of Controlled Substances: Rescheduling of Marijuana (April 28, 2026 hearing notice on proposed rule)](https://public-inspection.federalregister.gov/2026-08177.pdf)
### Continue Learning
For board and executive training, explore ACB’s [cannabis banking certification pathways](https://the-acb.org/cannabis-banking-professional).
Original PDF: https://the-acb.org/s/Bank-Board-Approvals.pdf
ACB editorial note: This article adapts previously published content. Regulatory statements should be reconfirmed at the time of publication. The article is educational, not legal advice.
