On April 23, 2026, Acting Attorney General Todd Blanche signed the formal order moving FDA-approved marijuana products and state-licensed medical marijuana to Schedule III of the Controlled Substances Act — the most significant change to U.S. federal drug policy in more than 50 years. For cannabis businesses, the rescheduling removes the application of Section 280E tax provisions (which denied deductions to Schedule I/II businesses) and opens federal research pathways. However, for financial institutions, the compliance landscape has not materially changed.
Schedule III status does not alter the Bank Secrecy Act compliance framework governing MRB banking. Cannabis transactions still involve a federally regulated controlled substance, and FinCEN’s 2014 guidance — requiring mandatory SAR filings, enhanced due diligence, and ongoing monitoring for all MRB customers — remains operative. No new banking guidance has been issued by FinCEN, the OCC, FDIC, or NCUA in connection with the rescheduling order. Financial institutions that had not previously opted into MRB banking face the same internal policy, board approval, and regulatory sign-off process they would have pre-rescheduling.
The broader context compounds the challenge. A March 2026 analysis (FCC Times) noted that FinCEN’s February 2025 enforcement operation targeting cash-intensive money services businesses along the Southwest border has maintained elevated AML scrutiny on high-risk cash corridors through 2026 — a category that overlaps significantly with cannabis retail. Banks that service MRBs face heightened compliance burdens: mandatory disclosure of MRB customer relationships in SARs, elevated transaction monitoring alert rates for cash-intensive deposits, and ongoing BSA programme documentation requirements.
The practical implication for compliance officers is that rescheduling signals a direction of travel but not an arrival. Institutions that wish to enter the cannabis banking market should begin policy drafting, board risk appetite discussions, and vendor procurement now — with the expectation that formal regulatory guidance and potential legislative action (SAFER Banking Act remains under discussion) may arrive within 12-18 months.
By FCCT Editorial Team
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