What triggers the filing of a Marijuana Priority SAR?

The filing of a Marijuana Priority SAR (Suspicious Activity Report) is triggered primarily when the financial institution believes that the marijuana-related business violates the enforcement priorities established by the Department of Justice (DOJ). These enforcement priorities are meant to outline specific criteria that reflect the federal government’s stance on marijuana-related activities, particularly given the complexities that arise due to differing state and federal laws.

When a financial institution identifies potential violations of these priorities, they must report this through the filing of a Marijuana Priority SAR to ensure compliance with the Bank Secrecy Act and to mitigate any risk associated with laundering proceeds from illegal activities. Therefore, recognizing a conflict with DOJ's guidelines is crucial for financial institutions in the context of marijuana-related businesses.

The other options do not directly relate to the criteria set forth for filing a Marijuana Priority SAR. Compliance with state law, employee count, or the location of the business, while potentially significant in other contexts, do not independently trigger the need for a Marijuana Priority SAR under federal guidelines.