Cannabis Compliance Services

Vanguard provides Marijuana Related Compliance Services to Financial Institutions, Cannabis Industry, and Municipalities who have Marijuana Related Businesses in their cities.

 

With our team of former Federal and State Regulators, Attorneys and Financial Crime Investigators, our experts are well equipped with the knowledge and experience your organization needs to be successful.

Meet The Team

Chuck Golden

A retired U.S. Navy Commander with over 33 years of experience in Intelligence. He has served as Counter Narcotics & Terrorism Liaison Officer for the U.S. Navy. He has worked U.S. and foreign military investigations as well as anti-money laundering joint-operations with U.S. Federal Law Enforcement agencies as well as International Law Enforcement agencies. 

Bob Flores

A former Chief Compliance Officer with over 25 years of financial investigations experience. As a Subject Matter Expert, Mr. Flores is highly experienced with Federal and State Regulations in matters of  Compliance, with emphasis in Anti-Money Laundering. Mr. Flores has worked with Federal Law Enforcement in matters of Anti-Money Laundering due to his extensive knowledge and expertise in banking. 

Cesar Valencia

A former U.S. Treasury Financial Crime Enforcement (FinCEN) Global Compliance Liaison. At U.S. Treasury FinCEN, Mr. Valencia advised representatives of other countries in planning, developing, and administering their Financial Intelligence Units. Mr. Valencia is a renowned Anti-Money Laundering Subject Matter Expert and Certified Fraud Examiner.

Financial Institutions

We have successfully worked with Banks and Credit Unions regarding Marijuana Related Business customers, including dispensaries and cultivators. 

     Our Services:

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BSA/AML Program Review

Vanguard's Cannabis AML Experts can review your institutions existing BSA/AML compliance program, policies and procedures and recommend enhancements to enable provision of services to cannabis-related clients. With our expertise in cannabis, we can ensure your institution is protected on all sides of Marijuana Related Business Risk. 

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BSA Independent Audit

Vanguard has teamed with Cannabis Industry Pioneers to create a custom Audit Program that will ensure your institution is prepared and aware of all risks related to banking Marijuana Related Businesses. 

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MRB Training

Vanguard has created one of the most comprehensive Marijuana Related Business training program for financial institutions. From general knowledge of MRBs to Anti-Money Laundering trends. Give your institution the knowledge it needs.

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Model & Data Validation

Vanguard can conduct a complete data validation of the bank’s core banking system and existing BSA/AML system in order to prepare the bank for the integration of the dispensary transaction data. We can also recommend enhancements to rule-sets and parameters within your existing BSA/AML system in order to prepare your institution for the integration of dispensary transaction data. 

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Enhanced Due Diligence

 Due diligence plays an important role in many facets of the Cannabis Industry.  Vanguard can conduct a thorough review of key documents and records related to a Marijuana Related Business. Our goal is to produce a document which gives us a comprehensive understanding of our customer and their transaction patterns.  Our Comprehensive EDD includes: Business Background, Transaction Analysis, Customer Risk Rating, Associated Risk, and Ultimate Beneficiary Ownership.

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MRB Risk Assessment

Vanguard has created one of the most comprehensive Marijuana Related Business Risk Assessments for financial institutions. The risk assessment will review and identify potential risk exposure with factors relating to the Bank’s size, location, customer base, types of accounts maintained, types of products and services provided, and types of transactions in which the customers engage.  Additionally, the Bank will assess the integrity of its internal policies, procedures, systems and internal controls in relation to the risks identified. 

Cannabis Industry

The cannabis industry is arguably in its infancy, especially when we consider growth projections.  Consequently, there are limited statistics specific to theft and diversion, but the threat is indeed real. At the end of the day, the market value associated with controlled substances, including cannabis, escalates risk. So what can you do? Industry players can anticipate and implement precautionary measures to mitigate losses by reviewing the details of dispensary and grower incidents. They can also take a lesson from the pharmaceutical industry; well-versed in the threats associated with Schedule I and II narcotics.

There are two keys to reducing diversion: protocol and protection. Vanguard can help your company with solutions for both.

Our Services:

Integrity & Expert Practices 

Protocol begins with hiring procedures including background checks and extreme vetting. Meticulous standard operating procedure is the next step. This should include tight inventory controls, employee rotation to prevent collusion, diversion response training, and physical/informational access restrictions. 

 

A top-notch access control system is absolutely fundamental to facility Protection. This provides time-stamped records of employee movement and allows management to make immediate adjustments to access permissions.  

Let Vanguard conduct a Protocol & Protection Audit to ensure your business is protected from Theft and Diversion. 

Anti-Money Laundering Audits

Independent AML Audits have long been required by Banks as a requirement for their highest risk customers such as Money Service Businesses and Cash Intensive Businesses. An Independent AML Audit conducted by industry experts will bring more transparency and trust between your business and your bank. 

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Dispensary Compliance Training

Vanguard has created one of the most comprehensive training programs for the Cannabis Industry. Ensure that your organization is in compliance  with Federal and State Regulations. A Comprehensive Training Program can make your organization more appealing to Banks, Investors, and Regulators. 

Seed to Sale Software Validation

Vanguard has the Cannabis and Transaction expertise to conduct a complete data validation of  your company's seed to sale system. Our extensive testing and model validation process will ensure your system is performing as required by regulation and industry best practice.

 

We can make recommendations based on industry standards to ensure your Dispensaries are reporting to their full capabilities and in compliance with Cannabis Regulations. 

Surveillance System & Security Audit

The objectives of the audit is to evaluate your company with policies and procedures related to the Cannabis Regulations, and to determine whether policies and procedures are consistent with best practices. This includes,but is not limited to footage retention, training requirements as well as security requirements set forth by the Police Department, Marijuana Bureau Ordinance and the State of California.

We will ensure compliance with regulations or ordinances pertaining to the requirements concerning the perimeter fencing, lighting, locks, windows, security cameras, security personnel, alarms, transportation, remote monitoring, electronic tract and trace, and record keeping.

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Cannabis Advisory Services

Vanguard has the experienced cannabis advisors combined with the knowledge of regulations to help with policy, process, preparation for audits and various other areas of your business. 

Municipalities

 

California’s black market for cannabis is at least three times the size of its regulated cannabis industry, as California continues struggle to tame a cannabis economy that has long operated in legal limbo.

This year, an industry-backed financial audit projected that roughly $8.7 billion will be spent on unregulated cannabis products in California in 2019, compared with just $3.1 billion spent on cannabis sold by legal businesses. That's $8.7 billion dollars of un-taxed cannabis revenue.

Vanguard has successfully worked with Cities throughout California regarding Cannabis Dispensaries, Manufacturers, Delivery Services,  Distributors and Cultivators. Our Anti Diversion Expertise allows us to review Cannabis Procedures and Transactions from an Audit and Anti-Money Laundering perspective which has long been our success with Banks for over 15 years.  

      Our Services:

Anti-Money Laundering Independent Audits

Reputation Risk is a something real that Municipalities and States have to deal with.

Anti-Money Laundering Independent Audits offer a deep dive into an area that would normally not be looked in a standard Financial Audit. Adding this to your already existing Cannabis Audit Schedule can act as an additional layer of protection against Money Laundering. Let our experts help you better understand your Cannabis Businesses operating in your city. 

Anti-Diversion Enforcement

An audit, conducted by the United Cannabis Business Assn., found approximately 2,835 unlicensed dispensaries and delivery services operating in California. By comparison, only 873 cannabis sellers in the state are licensed, according to the Bureau of Cannabis Control. 

With highly experienced investigators on staff, let Vanguard help you find illegal dispensaries in your city that are not paying taxes and taking sales away from those legitimate dispensaries who do. 

Vanguard has been providing this type of service to Money Service Businesses and Intellectual Property Industry for over 25 years.

Due Diligence

Comprehensive Due Diligence of Cannabis Businesses operating in your city is crucial to success.

Due diligence plays an important role in many facets of the Cannabis Industry.  Vanguard can conduct a thorough review of key documents and records related to a Cannabis Business.

With over 15 years of Enhanced Due Diligence in the Anti-Money Laundering space, our investigators are well versed and experienced in helping gather information in order to better understand the risk involved. 

California Municipalities lose $ Billions of dollars in Tax Revenue annually to Diversion.

Vanguard has the Cannabis, Transaction , and Investigation expertise to conduct a complete Data & Diversion Validation of your City's Licensed Cannabis Businesses. From Seed to Sale Software Systems, Video Surveillance Systems, to Cannabis Integrity Practices . We can ensure your City's Dispensaries are operating and reporting in compliance with Cannabis Regulations. 

Diversion Audits

The fundamental purpose of the audit is to provide independent assurance that management has, in its financial statements, presented a “true and fair” view of a company’s financial performance and position. It underpins the trust and obligation of stewardship between those who manage a company and those who own it or otherwise have a need for a clear and objective view. 

A rigorous audit process will also, almost invariably, identify areas where management may improve their controls or processes, further adding value to the company by enhancing the quality of its business processes.

Financial Audits

We have provided consulting services to Banks, Money Service Businesses and Federal Regulators. Let us help you with deadlines or backlog which often cause other areas of your organization to suffer.

From applications, on-boarding new licensees, to day to day operations. We can provide the temporary staff augmentation which can help alleviate some of the stress and workload related to the Cannabis Industry in your city. 

Consulting Services

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