By Habit 420
Oregon Cannabis Connection
The governors of the first four states to legalize recreational marijuana sent a letter on April 3rd to the Trump administration asking that he be cooperative with the min any enforcement activities in their states. In a unified letter to Atttorney General Jeff Sessions and Treasury Secretary Steve Mnuchin, the Governors explain there concerns and explain that uncoordinated enforcement would be disruptive, at the least.
“We ask the Trump Administration to engage with us before embarking on any changes to regulatory and enforcement systems,” the letter says. “Providing the necessary framework for state regulatory programs centered on public safety and health protections.”
They also implore him to stick with the Cole Memorandum, stating in the letter, “The balance struck by the 2013 Department of Justice Cole Memorandum (Cole Memo) has been indispensable.”
They governors want to continue the progress achieved. They tell Trump that the Cole Memo allowed the states to develop, “Robust regulatory structures that prioritize public health and public safety, reduce inequitable incarceration and expand our economies.”
They also mention the effectiveness of the Financial Crimes Enforcement Network (FinCEN) guidance from the U.S. Treasury Department. The letter mentions that this guidance and the Cole memo provided, “The foundation for state regulatory systems and are vital to maintaining control over marijuana in our states.”
Lets also hope these governors also send a letter to congressional leaders asking for renewing the Rohrabacher-Farr Amendment in the budget. That is the amendment that prevents reimbursement of DOJ enforcement in legal medical cannabis states upon legal medical cannabis business activities.
Letter from the “First Four”:
April 3, 2017
Attorney General Jeff Sessions
U.S. Department of Justice
950 Pennsylvania Ave.,
NW Washington, DC 20530
Secretary Steve Mnuchin
U.S. Department of the Treasury
NW 1500 Pennsylvania Ave.,
Washington, DC 20220
Attorney General Sessions and Secretary Mnuchin:
As governors of states that have legalized marijuana in some form, we ask the Trump Administration to engage with us before embarking on any changes to regulatory and enforcement systems. The balance struck by the 2013 Department of Justice Cole Memorandum (Cole Memo) has been indispensable – providing the necessary framework for state regulatory programs centered on public safety and health protections.
We understand you and others in the administration have some concerns regarding marijuana. We sympathize, as many of us expressed apprehensions before our states adopted current laws. As governors, we have committed to implementing the will of our citizens and have worked cooperatively with our legislatures to establish robust regulatory structures that prioritize public health and public safety, reduce inequitable incarceration and expand our economies.
The Cole Memo and the related Financial Crimes Enforcement Network (FinCEN) guidance provide the foundation for state regulatory systems and are vital to maintaining control over marijuana in our states. Overhauling the Cole Memo is sure to produce unintended and harmful consequences. Changes that hurt the regulated market would divert existing marijuana product into the black market and increase dangerous activity in both our states and our neighboring states. Likewise, without the FinCEN guidance, financial institutions will be less willing to provide services to marijuana-related businesses. This would force industry participants to be even more cash reliant, posing safety risks both to the public and to state regulators conducting enforcement activity. The Cole Memo and FinCEN guidance strike a reasonable balance between allowing the states to enact reasonable regulations and the federal government’s interest in controlling some of the collateral consequences of legalization.
Twenty-eight states, representing more than 60 percent of Americans, have authorized some form of marijuana-related conduct. As we face the reality of these legalizations, we stand eager to work with our federal partners to address implementation and enforcement concerns cooperatively. The Cole Memorandum and the associated FinCEN guidance are critical to the success of any collaboration. We look forward to working with you and your administration. We stand ready to have further discussion on how these important federal policies work in our states.
Bill Walker Governor State of Alaska
John Hickenlooper Governor State of Colorado
Kate Brown Governor State of Oregon
Jay Inslee Governor State of Washington
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