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Top 5 Medical Marijuana Dispensary Infractions

 

Here are the Top 5 Medical Marijuana Dispensary Infractions:

  1. The license does not immediately input all marijuana and marijuana product(s) into the State-mandated inventory tracking system and account for all variances
  2. The dispensing facility does not have accurate or updated tracking logs for visitors, security and/or waste
  3. The business does not have all required financial business documentation available as required (federal and state)
  4. Marijuana and marijuana product sold to patients does not include all required public health and safety warning statements as required by law
  5. Surveillance cameras do not have clear, unobstructed views of the license premise and blind spots or sight obstructions exist

Inventory is one of the most challenging aspects of running a marijuana business. Marijuana product and/or cash diversion is the primary concern of regulators and a pillar of Cole Memo compliance. Is inventory reconciled daily between physical counts, POS inventory, state-mandated tracking inventory and the accounting system for related tax payments? This is the number one infraction across all marijuana license types.

Logs, logs, logs… it’s one of the easiest violations for regulators to find. Any missing information on facility tracking logs – including waste, security & surveillance or application & production logs, often opens the door to further scrutiny and deeper investigation. If tracking logs are insufficient or incomplete, there is a high probability that required business records for the marijuana license are lacking as well.

Required financial documentation is imperative to survival. Currency Transaction Reports (Form 8300), 280e compliance and physical access to all financial and inventory records must be in place and readily available for IRS and State investigators. This area is the coming storm for most operational marijuana businesses.

Public safety warnings for marijuana and marijuana product are required for public health & safety. Many marketing teams are making logos bigger and required warning statements smaller, or removing entirely. Many state regulators are just starting to catch up on required labeling & packaging. Ensure warning statements are conspicuous and unobstructed. All marijuana and marijuana product should pass the “playground” test. Avoid all cheap pop-top bottles as well.

For more information on top compliance infractions for marijuana businesses, please contact us today.  We’ve inspected more than 600 operational licenses.  We can help.