In 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued guidance clarifying how financial institutions can provide services to marijuana-related businesses (“MRBs”) in a manner consistent with their obligations under the Bank Secrecy Act (“BSA”). The FinCEN guidance primarily covered three topics. First, it provided a list of actions that a financial institution should undertake when conducting its customer due diligence.Second, it required that all financial institutions with, or By