Almost three weeks before FinCEN’s quarterly marijuana update, the United States Attorney for Oregon described Oregon’s marijuana regime as “out of control”. He noted that his office is “alarmed by revelations from industry representatives, landowners, and law enforcement partners describing the insufficient and underfunded regulatory and enforcement structure governing both recreational and medical use” and that “overproduction is rampant and the illegal transport of product out of state—a violation of both state and federal law—continues unchecked.” He concluded with “it’s time for the state to wake up, slow down, and address these issues in a responsible and thoughtful manner.” The press release is available at https://www.justice.gov/usao-or/pr/us-attorney-statement-release-2018-hidta-marijuana-insight-report
If I was, or was providing guidance to, an Oregon marijuana-related business or someone looking to invest in or provide banking services to an Oregon MRB, I would be very, very concerned that the US Attorney sees the regime and its actors as being out of control.