Live Life Federal Credit Union
The NCUA issued its first-ever penalty against a credit union for Anti-Money Laundering compliance deficiencies in connection with cannabis banking services. Live Life Credit Union had been servicing approximately 150 marijuana-related business customers using manual compliance processes rather than automated monitoring systems. The NCUA's order required Live Life to implement automated compliance systems with specific capabilities including reconciliation of point-of-sale data, monitoring of adverse public information, verification of licensure changes, and monitoring of unusual transaction activity. This action represents a significant precedent as the first NCUA enforcement action specifically targeting AML failures in the cannabis banking space, signaling heightened regulatory expectations for financial institutions serving MRBs.
Verified from source: The NCUA issued a Stipulation and Consent to Cease and Desist Order against Live Life Federal Credit Union on February 19, 2021, for AML compliance failures related to servicing approximately 150 MRB customers using manual compliance processes instead of required automated systems. The order required implementation of automated monitoring, a third-party look-back, accurate CTR filing, and suspension of new MRB accounts.
- Sets precedent for NCUA enforcement in cannabis banking compliance
- Signals that manual compliance processes are insufficient for high-risk banking relationships such as MRBs
- Financial institutions serving cannabis or other high-risk fintech-adjacent verticals must invest in automated compliance and monitoring systems
- BaaS providers facilitating access to banking for cannabis-adjacent businesses face heightened regulatory scrutiny