Cogent Law

Cannabis rescheduling continues to dominate headlines, policy discussions, and boardroom conversations. Yet for many financial institutions, the real implications are being misunderstood, or worse, oversimplified.

A pragmatic analysis of where cannabis banking is heading in 2026 and why regulatory uncertainty around rescheduling, intoxicating hemp, and interagency guidance is creating both risk and opportunity for financial institutions.

Cannabis banking didn’t become “normal” just because more states legalized it. The operating reality for banks and credit unions is still defined by regulatory ambiguity, examiner variability, and a compliance framework that has not kept pace with market complexity.

Introduction A recent decision from the U.S. District Court for the Northern District of California, Sequeira v. United States Department of Homeland Security, No. 4:22-cv-07996-HSG, offers important clarification on the scope of the Right to Financial Privacy Act (RFPA) and its applicability to money transmitters and similar non-bank financial service providers. The ruling exposes a

A pragmatic recap of what Money Transmitter Licensing (MTL) really entails and why state-by-state compliance is emerging as one of the most decisive competitive barriers for fintechs and crypto companies entering the U.S. market. Money Transmitter Licensing has become a structural filter for which fintech and crypto companies can operate and scale in the United