Our Work In Depth

1.

In our role communicating with law enforcement, there is still an active movement afoot by U.S. regulators to tap the brake pedal on cross border activity; representing unchartered territory especially as it relates to cannabis businesses using the Canadian public markets to fund U.S. state legal operations. Scrutiny has also been broadened to include ancillary businesses which have previously flown under the radar. PH&S is actively engaged in facilitating and providing feedback among state Attorneys General, regulators, and financial institutions as it relates to interstate commerce, cannabis companies trading on Canadian public markets and related investor activity.

2.

PH&S continues to facilitate and participate in meaningful, ongoing dialogue with state Attorneys General and federal agencies to maintain lines of communication when policy considerations are being evaluated. Regulators require ongoing and credible input to assess policy positions with the current presidential administration and future administrations regardless of party lines. This also applies to state Attorneys General on issues including but not limited to financial services, interstate commerce, foreign investment and other emerging issues which may lead to legal challenges moving forward.

PH&S will continue to take the lead on maintaining this dialogue from a perspective of public health & safety, consumer protection, anti-money laundering and rule of law in order to safeguard industry priorities. The input and recommendations of PH&S members will be brought to the conversation.

3.

Monitor and continue to advance:

  • Financial Crimes Enforcement Network (FinCEN) guidance protection
  • Protection of any assault on marijuana banking
  • The rationale to eliminate 280E
  • Advance the STATES Act or comparable proactive legislation

While there are many issues that concern the industry, the above are central to maintain state engagement. Federal departments and state Attorneys General continue to conduct reviews at the state level and need to be kept apprised in these areas to defend against potential federal overreach.

4.

PH&S will facilitate involvement with state Attorneys General on international regulatory issues and barriers to market entry.

  • International treaties, customs and border enforcement actions, and Department of Justice reviews of decades old statutes and input from International Narcotics and Law Enforcement (INL) are increasingly intensifying; scrutiny is ascending to international investment and business ventures embracing the legal cannabis industry.

5.

PH&S is engaging in a line of defense against industry opposition groups and businesses who are seeking to score “wins” against the cannabis industry at the state level and leading opposition efforts against adversaries.

  • Briefings have been held with states’ Attorneys General with regard to the various, misleading and non-factual opposition groups that are promulgating to policymakers and law enforcement.

PH&S is accelerating outreach to credible law enforcement operations and organizations, expanding the foundation from which state Attorneys General have previously weighed in on the issues of public health & safety, anti-money laundering, consumer protection, and rule of law. PH&S is also making certain that policymakers and regulators are aware of non-factual or derogatory statements that support alternative agendas.