Business self-check

Do legal entity names, trade names, ownership records, licenses, tax registrations, and banking records consistently identify the same operating structure?

Is the current ownership list/cap table (or equivalent ownership record) accurate and complete, including direct and indirect owners, financial interests, control relationships, and identification of any person meeting Ohio's 10%-or-greater ownership disclosure threshold (O.A.C. 1301:18-3-04)?

Citation checked 2026-10-11

Before entering or completing ownership, financial-interest, control, entity-name, or trade-name changes, does the operator identify applicable DCC prior-approval requirements (O.A.C. 1301:18-3-06 — prior approval required for ownership changes of 10% or more, aggregated per calendar year) and retain evidence of application and written approval?

Citation checked 2026-10-11

Can the company document source of initial and material subsequent capital, loans, and investor funds?

Is there a documented process to keep licenses, permits, registrations, and required ownership disclosures current?

Does each financial institution used by the company know the nature of the cannabis-related business and permit the relationship?

Are all operating, payroll, tax, merchant, lending, and investment accounts inventoried with clear ownership and authorized signers?

Does the company have a process for responding promptly and consistently to bank due-diligence requests?

Are bank-imposed conditions, deposit requirements, transaction restrictions, reporting requirements, and fees documented and monitored?

Is there a contingency plan for account closure, payment-service disruption, or loss of a key banking relationship?

Can management explain cash receipts and deposits as a percentage of revenue, and reconcile that pattern to licensed locations, POS activity, METRC data, and expected peer/business activity?

Do owners and finance personnel understand that cannabis banking commonly involves enhanced due diligence, ongoing transaction monitoring, recurring information requests, and bank-side SAR reporting consistent with applicable FinCEN guidance, and is responsibility assigned for responding accurately and promptly?

Are cash receipts, drawers, vaults, transfers, deposits, and variances reconciled under documented procedures?

Are dual control, access restrictions, segregation of duties, and physical-security controls used for material cash movements?

Are armored-car, cash-vault, merchant, ATM, ACH, debit, and other payment providers approved and monitored before use?

Can the company trace material incoming and outgoing funds to a legitimate business purpose and supporting documentation?

Has the operator prohibited or formally risk-approved payment arrangements that could disguise the underlying cannabis transaction — including cashless-ATM structures or merchant-category-code workarounds — from a financial institution or payment network?

Are owners, control persons, material investors, lenders, and other high-risk counterparties identified and subject to risk-based due diligence?

Does the company have a risk-based process for sanctions screening of relevant owners, control persons, counterparties, and vendors?

Are financial-crime red flags documented for staff, including unusual payments, third-party funding, unexplained cash, structuring indicators, fraud, or identity concerns?

Is there a documented internal escalation path for suspected fraud, illicit finance, sanctions concerns, identity issues, or suspicious counterparties?

Can the company explain its business model, revenue sources, major counterparties, and expected transaction patterns in a way a bank can readily understand?

Are material vendors and service providers subject to documented onboarding and risk-based due diligence?

Are high-risk vendors, management companies, consultants, payment intermediaries, and related parties identified for enhanced review?

Do contracts give the company adequate documentation, audit, termination, compliance, and data-access rights for material providers?

Are leases, management agreements, loans, and other transactions with owners or related entities fully disclosed, documented, and supported as bona fide, arm's-length business arrangements?

Are inventory/seed-to-sale records, point-of-sale data, deposits, and general-ledger revenue periodically reconciled with documented exceptions?

Are tax obligations, filings, payment deadlines, and tax-payment accounts assigned, documented, and monitored?

Are records needed for regulators, banks, auditors, tax authorities, and internal investigations retained in an organized and retrievable manner?

Is compliance responsibility assigned to a named person who has sufficient access, independence, and authority to stop or escalate activity that may violate law, license requirements, banking conditions, or internal policy?

Do relevant employees receive documented training on cash controls, fraud/red flags, banking requirements, regulatory obligations, and escalation procedures?

Are compliance issues, control failures, bank concerns, losses, fraud events, and regulatory findings tracked through remediation and closure?

Has the operator documented, with its tax advisor, how IRC §280E applies to each line of business: medical activity under a state medical license (outside §280E under the April 2026 Schedule III order) and adult-use activity (still subject to §280E pending a final federal decision), including the allocation method for dual-use operations and any decision on amended or protective claims for prior years?

Citation checked 2026-10-11