In the latest episode of Payments Pros, hosts Keith Barnett and Carlin McCrory are joined by Jean Gonnell and Agustin Rodriguez, co-leaders of Troutman Pepper’s Cannabis practice, to discuss the legal complexities that financial institutions face when dealing with the cannabis industry.

Jean and Agustin give a high-level overview of the basics of cannabis, including federal and state regulations, and the specific expectations for financial institutions operating in this space. They also explain the rigorous state-level regulatory systems for marijuana, including seed-to-sale tracking, testing requirements, and security measures.

Our guests examine the impact of cannabis regulation on financial institutions. They discuss the challenges posed by the Bank Secrecy Act, money transmitter laws, and the Money Laundering Control Act for financial institutions serving marijuana-related businesses.

Transcript: Chronic Payments: Unraveling the Complexities of Cannabis Banking (PDF)


Our Cannabis Practice provides advice on issues related to applicable federal and state law. Marijuana remains an illegal controlled substance under federal law.

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Photo of Keith J. Barnett Keith J. Barnett

Keith’s experience representing clients in the financial services industry as a litigation, compliance, regulatory, investigations (internal and regulatory), and enforcement attorney spans 20 years. Keith represents clients against government regulators (CFPB, FTC, SEC, CFTC), industry regulators (FINRA), and private litigants in federal courts…

Keith’s experience representing clients in the financial services industry as a litigation, compliance, regulatory, investigations (internal and regulatory), and enforcement attorney spans 20 years. Keith represents clients against government regulators (CFPB, FTC, SEC, CFTC), industry regulators (FINRA), and private litigants in federal courts, state courts, and before arbitration and administrative law panels in the financial services industry.

Photo of Carlin McCrory Carlin McCrory

Carlin is a regulatory, compliance, and payments attorney with experience representing financial institutions, fintechs, lenders, debt collectors, payment processors, neobanks, virtual currency companies, and mortgage servicers.

Photo of Jean Smith-Gonnell Jean Smith-Gonnell

Jean focuses her practice on the cannabis industry. She has extensive experience in medical marijuana, retail marijuana, as well as hemp and CBD products. Jean also has substantial experience in trials and administrative hearings, where she has achieved remarkable success in helping her…

Jean focuses her practice on the cannabis industry. She has extensive experience in medical marijuana, retail marijuana, as well as hemp and CBD products. Jean also has substantial experience in trials and administrative hearings, where she has achieved remarkable success in helping her clients succeed in a complex and ever-changing legal landscape.

Photo of Agustin Rodriguez Agustin Rodriguez

Agustin is sought after by clients for his strategic counsel on their most challenging competitive and regulatory compliance issues, including tobacco Master Settlement Agreement issues, federal and state enforcement investigations, licensing and excise tax issues, developing compliance programs, and evaluating advertising and marketing…

Agustin is sought after by clients for his strategic counsel on their most challenging competitive and regulatory compliance issues, including tobacco Master Settlement Agreement issues, federal and state enforcement investigations, licensing and excise tax issues, developing compliance programs, and evaluating advertising and marketing practices. A partner in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group as well as its Tobacco and Cannabis law practices, he represents manufacturers, distributors, retailers, and suppliers in all aspects of their businesses, including regulatory compliance, FDA requirements, administrative disputes involving federal or state governmental entities, mergers and acquisitions, commercial agreements, and taxation matters.