Audit Best Practices by Nick Youngson CC BY-SA 3.0 Alpha Stock Images

Fusion Bank works around the clock to insure your money is where you want it to be and off the streets. It takes a dedicated team of professional, diligent, highly trustworthy individuals to keep the Fusion Bank engine running smoothly and deliver the features and benefits you need to operate and grow your business. With careful adherence to strict government guidelines, Fusion Bank can give you the peace of mind you need to protect your investment. Compliance is our #1 priority in everything we do.

Onsite Inspections:

Prior to the establishment of your bank account, the bank or its authorized designees shall perform an onsite site inspection.

  • The onsite inspector will only schedule appointments directly with principal signer(s).
  • Onsite audits can range between 1 -3 hours depending on the size of the facility.
  • Typical retail dispensary audits are 90 min.
  • Combined business types Grower/Dispensary may take 120-180 min or more.
  • Information collected at the location may include the following:
  • Interior and exterior walkthrough of business and supporting buildings.
  • Photos of the front, all sides, rear and inside of locations.

An example of auditor’s on-site review may include: POS system, video system, disposal, medical testing, hardware backup systems, signage, secure access, employee procedures, client procedures, HIPPA compliance and more. After the onsite inspection is performed and all information complete the inspector will deliver their inspection report to the bank for approval or denial of service. *The Client can obtain a copy of the inspection report upon request.

2014 FinCEN Guidelines: 

  • Verify with the appropriate state authorities whether the business is duly licensed and registered
  • Review the license application (and related documentation) submitted by the business for obtaining a state license to operate its marijuana-related business
  • Requesting from state licensing and enforcement authorities available information about the business and related parties
  • Develop an understanding of the normal and expected activity for the business, including the types of products to be sold and the type of customers to be served (e.g., medical versus recreational customers)
  • Ongoing monitoring of publicly available sources for adverse information about the business and related parties;
  • Ongoing monitoring for suspicious activity, including for any of the red flags described in this guidance
  • Refreshing information obtained as part of customer due diligence on a periodic basis and commensurate with the risk.
  • File required suspicious activity reports (“SARs”)

Fusion Bank Policies, Guidelines and Compliance:

  • Scheduled ongoing site inspections
  • Scheduled and unscheduled audits
  • Periodic document review based on a number of factors including but not limited to:
    • Name Change
    • Location Change
    • License Modification
  • Continual monitoring of suspicious or illegal activity reported and unreported examples:
    • The business receives substantially more revenue than may reasonably be expected given the relevant limitations imposed by the state in which it operates.
    • The business receives substantially more revenue than its local competitors or than might be expected given the population demographics.
    • The business is depositing more cash than is commensurate with the amount of marijuana-related revenue it is reporting for federal and state tax purposes.
    • The business is unable to demonstrate that its revenue is derived exclusively from the sale of marijuana in compliance with state law, as opposed to revenue derived from (i) the sale of other illicit drugs, (ii) the sale of marijuana not in compliance with state law, or (iii) other illegal activity.
    • The business makes cash deposits or withdrawals over a short period of time that are excessive relative to local competitors or the expected activity of the business.
    • Deposits apparently structured to avoid Currency Transaction Report (“CTR”) requirements.
    • Rapid movement of funds, such as cash deposits followed by immediate cash withdrawals.
    • Deposits by third parties with no apparent connection to the accountholder.
    • Excessive commingling of funds with the personal account of the business’s owner(s) or manager(s), or with accounts of seemingly unrelated businesses.
    • Individuals conducting transactions for the business appear to be acting on behalf of other, undisclosed parties of interest.
    • Financial statements provided by the business to the financial institution are inconsistent with actual account activity.
    • A surge in activity by third parties offering goods or services to marijuana-related businesses, such as equipment suppliers or shipping servicers.
    • The business is unable to produce satisfactory documentation or evidence to demonstrate that it is duly licensed and operating consistently with state law.
    • The business is unable to demonstrate the legitimate source of significant outside investments.
    • A customer seeks to conceal or disguise involvement in marijuana-related business activity. For example, the customer may be using a business with a non-descript name (e.g., a “consulting,” “holding,” or “management” company) that purports to engage in commercial activity unrelated to marijuana, but is depositing cash that smells like marijuana.
    • Review of publicly available sources and databases about the business, its owner(s), manager(s), or other related parties, reveal negative information, such as a criminal record, involvement in the illegal purchase or sale of drugs, violence, or other potential connections to illicit activity.
    • The business, its owner(s), manager(s), or other related parties are, or have been, subject to an enforcement action by the state or local authorities responsible for administering or enforcing marijuana-related laws or regulations.
    • A marijuana-related business engages in international or interstate activity, including by receiving cash deposits from locations outside the state in which the business operates, making or receiving frequent or large interstate transfers, or otherwise transacting with persons or entities located in different states or countries.
    • The owner(s) or manager(s) of a marijuana-related business reside outside the state in which the business is located.
    • A marijuana-related business is located on federal property or the marijuana sold by the business was grown on federal property.
    • A marijuana-related business’s proximity to a school is not compliant with state law.
    • A marijuana-related business purporting to be a “non-profit” is engaged in commercial activity inconsistent with that classification, or is making excessive payments to its manager(s) or employee(s)

For more information or to apply, go to: Fusion Bank

***You can open an account immediately with a zero balance so you can experience the ease of our platform.  This allows you to see your real bank account online and learn how to navigate through the normal banking processes for bill pay, transfer to other accounts, pay vendors, send outgoing wires and receiving incoming wires. You will not be able to deposit any funds until your KYC application has been processed and cleared. Protection Status