Alison Jimenez quoted on Sentencing Guideline Implications


Alison Jimenez, President of Dynamic Securities Analytics, Inc., was quoted in a May 16, 2017 moneylaundering.com article titled “New Sentencing Guidelines Signal Consequences for Banking Marijuana Firms” by Valentina Pasquali. The article focused on Attorney General Sessions Department Charging and Sentencing Policy issued on May 10th which Pasquali notes “directs federal prosecutors to pursue criminal charges against the “most serious, readily provable” offenses, or those that carry the heftiest standard penalties, such as mandatory minimum sentences.”

In the article, Ms. Jimenez advised financial institutions to re-evaluate their risk tolerance for marijuana-related businesses (‘MRBs’) in light of the new guidelines. Ms. Jimenez further suggested that banks review account holders to determine if they have any any undeclared MRBs as customers, and to be especially focused on fund transfers across state lines which could implicate the Cole memo priority of diverting marijuana from legal states to illegal states.

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Prior DSA blog posts regarding marijuana and AML issues:

Marijuana SARs has International Implications

Who is Filing Marijuana SARs? New Data May Surprise You.

Securities Brokers have (Relatively) Open Arms to Marijuana