Cannabis Economy

John Vardaman joins us and discusses his involvement in the release of the the third Cole memo and FinCen Guidance which supported the initial memos which of course laid out guidance from DOJ to state attorney’s general. John lays out that Justice and Treasury still needed to deal with the fact that based on the Controlled Substances Act, the monies generated from state legal cannabis were (and still are) considered criminal proceeds based on federal money laundering and bank secrecy act laws aided of course with a Patriot Act kicker. Which John actually has experience with as he began his career in government just weeks before 9/11 and explains that his job following that day was following the money- something he also had to do on the ground in Iraq. Thanks to Boveda & MCBA for supporting the episode.