The Financial Crimes Enforcement Network (FinCEN) has quietly released its latest update on marijuana-related business (MRB) banking metrics, covering activity through December 2024.
The update is notable because the agency had largely stopped publishing quarterly statistics after 2022, making this release the first substantial update in years.
The data stems from “suspicious activity reports” (SARs) that banks and credit unions are required to file when servicing marijuana businesses. These requirements originate from the 2014 FinCEN guidance, issued alongside Department of Justice memos that outlined federal enforcement priorities. That guidance has never been updated, despite enormous changes in the legal marijuana landscape since then.
Under the rules, financial institutions must file an initial SAR within 30 days of onboarding a marijuana client, followed by continuing SARs every 90 days. They’re also directed to file specific types of reports—labeled “marijuana limited,” “marijuana priority,” and “marijuana termination”—depending on circumstances, in addition to standard currency transaction reports. Banks have long cited these requirements as a reason for the high fees charged to marijuana businesses, noting that the cost of compliance is substantial even though law enforcement rarely acts on the information collected.
That reality raises questions about why the system remains in place. Despite more than a decade of reporting, there is little evidence that the SAR data has been used in any meaningful way. The obligations continue to create paperwork and costs for banks and marijuana businesses alike, while offering little apparent benefit to regulators or the public.
FinCEN’s new release offers a snapshot of the current banking landscape. Roughly 80% of SARs fall under the “marijuana limited” category, meaning the bank is simply acknowledging that a transaction involved a marijuana business without flagging suspicious activity. About 13% of filings were “marijuana termination” SARs, which indicate that a financial institution has ended a relationship with a client. The data also shows that SAR filings have nearly doubled since 2015, while the number of financial institutions serving the marijuana sector has grown more modestly. As of 2024, 182 credit unions and 816 banks were actively filing reports.
The numbers reinforce a broader reality: basic banking services are increasingly available to marijuana businesses, even if payment processing and other financial services remain limited. Still, with Congress slow to move on legislation like the SAFE or SAFER Banking Acts, the outdated FinCEN rules continue to govern the space—leaving financial institutions acting as compliance officers for federal marijuana policy, even as state-legal markets continue to expand.
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