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Experience Connections Knowledge

January 16, 2018 | Nicole Meisner

Marijuana Banking & Payments: The Impact of AG Sessions’ Recent Memo

On January 4, 2018, U.S. Attorney General Sessions formally rescinded guidance issued by the Department of Justice (DOJ) during the Obama administration related to the DOJ’s approach to the enforcement of state-legalized marijuana activity.   Sessions replaced the former guidance by issuing a memo (“Sessions Memo”) that instructs U.S. Attorneys to “follow the well-established principles that …

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November 16, 2017 | Nicole Meisner

Technology Platform Providers and the Risk of Money Transmission

A recent trend that we are encountering frequently is software and internet-based platform providers (“providers”) venturing into the world of payments—sometimes unwittingly. A typical scenario looks something like this: A provider develops a platform that assists merchants (such as hair salons, utility providers, or medical offices) accept electronic payments from the merchant’s customers. Most commonly, …

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