A post on the FCPA Blog on 30th October (and which originally appeared on a Baker McKenzie blog) says that if the DoJ or state regulators discover that a state licence was acquired through corrupt means, the licence will not provide any protection from US federal law enforcement.  The post says that there is no suitable corruption risk guidance on potential red flags with respect to the state-legal marijuana industry, and seeks to be the first step in providing such guidance.  It lists factors which may make a state licensing scheme more susceptible to corruption and should be taken into account when evaluating the relative corruption risks in any particular state.  It then suggests some red flags indicating a business may have obtained a state licence improperly.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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