Cannabis Conversation With Avis Bulbulyan of SIVA Enterprises

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AUTHOR: Heather Allman



Cannabis Conversation With Avis Bulbulyan, CEO of SIVA Enterprises


The U.S. House of Representatives is set to vote on the MORE Act that could pave the way for the legalization of cannabis at the federal level. While it is not certain that act will ultimately become law, this year’s Presidential election could certainly have a dramatic impact on investments in and regulations for cannabis-related businesses. 

A recent poll found 71% of investors are primarily concerned about the effect a contested U.S. presidential election will have on the stock market. 

In light of the market’s potential volatility, Avis Bulbulyan, CEO at cannabis consultancy SIVA Enterprises, believes the cannabis industry is one of the most secure investments due to the steady demand despite the current recession. 

Avis recently spoke to Reuters about how cannabis stocks have rallied since a turbulent second quarter and believes we are likely to see a lot of big mergers and acquisitions proceed in the industry as investors regain confidence. According to the Reuters article,

“As pot demand surged in lockdowns, stock prices have recovered, raising prospects that funding will be available for some deals.” 

In the article, Bulbulyan agreed, predicting “You’ll still see a lot of the same funding sources but they’re going to be much more diligent and cautious with their dollar.”

As a policy and business consultant, Avis Bulbulyan helps emerging cannabis companies navigate the evolving industry with its regulatory hurdles.

His on-the-ground perspective combined with his expertise on policy makes him a great source for predicting the trajectory of the industry.

In the July 8, 2020 article Cannabis firms see jump in insurance costs to protect leaders as investors sue, Shariq Khan and Nichola Saminather reported:

Some of the biggest cannabis companies, including Medmen Enterprises, Canopy Growth, CannTrust Holdings, Aphria Inc and Columbia Care, have faced shareholder litigation, accusing leaders of false claims, failing to act in the interest of all shareholders and attempts to defraud investors.

The lawsuits are yet another sign of souring sentiment against an industry that has failed to deliver on promises of boundless growth. And the rising costs are another headwind for companies already shuttering operations and cutting jobs due to slower-than-expected demand.” 

Cannabis companies still manage to generate investor excitement because 2020 has seen cannabis legalized for recreational use in 11 U.S. states, as well as the District of Columbia, and authorized for medical use in over 30 states.

Simultaneously, investors have faced market downturns and losses –large and small, and they are increasingly likely to target cannabis companies.

Avis Bulbulyan of cannabis consultancy Siva Enterprises, estimates a 50% spike in litigation.

Despite these facts, during this COVID-19 pandemic, cannabis has emerged triumphant and use has spiked. 


Why? What’s the appeal? Where’s it all headed? Why invest in the current market? Let’s ask our esteemed guest.

On October 29, 2020, I talked with Avis Bulbulyan about the reliability of cannabis investments considering the current market and U.S. business climate. 

Avis Bulbulyan, CEO of SIVA Enterprises


Cannabis Law Report: Do you have a life motto, mantra, or favorite quote?

Avis Bulbulyan:  Serve people and people will serve you. And never ask someone to do something you wouldn’t do yourself.  

CLR: How did you get into the Cannabis space, and investing specifically?

Avis Bulbulyan:  Things evolved more naturally for me.  I started off at the ground level of the industry.  That led to opportunities across other sectors.

That then led to licensing work at the state level.  Then the success of that led to consulting others.  

Through the different projects across different markets, I started seeing what works and what doesn’t and how different variables impact the businesses.  

With all the different work I was doing, my network grew exponentially and with investing, I was incredibly fortunate to work with some of the greatest business minds in the country and really learn what drives their decisions and how they look at different investments. 

For me, I was learning as much as I was teaching.   

CLR: Briefly tell me about your ultimate end game in the Cannabis industry.

Avis Bulbulyan: The end game is to leave behind a legacy and hopefully leave a positive mark on the industry. 

Not many times in one’s life are we in a position to be involved in the creation of an industry in a meaningful way.

With this industry, I’ve been incredibly fortunate to be as involved and as deep in the industry as I’ve been. 

To look back decades from now and be able to say I had a hand in it, that would have made all the sacrifices worth it.

SIVA Enterprises

CLR: What is the mission and vision behind SIVA Enterprises? How does it align with your personal mission?

Avis Bulbulyan:  SIVA has turned into a platform for me that allows me to reach the different corners of the industry.  The way I look at it, there’s all the time in the world in the future to compete.  Right now it’s about helping build the industry with sensible regulations and inclusion.  

For me, the different evolutions that SIVA has gone through as a company and me as an individual, it’s turned into a platform that gives me the flexibility to take the company in whatever direction that has the most meaningful impact on the industry.  

CLR: Mainly, there are people-centric or profit-centric reasons for being in the Cannabis sphere.

How do you reconcile the two in order to maintain a balance? Why is it important to have that balance?

Avis Bulbulyan:  If you chase the profits, you won’t get far.  This industry or any industry has to be able to serve the people first. 

With this industry, balancing it becomes a little trickier than other industries because of the grass roots nature of it.  This industry is in a transitional stage right now and many will be left behind.

Most will be left behind because of the unwillingness to change.  There has to be a balance in the approach and execution.  

CLR: Tell me about the 2020 cannabis year to date, and take on the current national Cannabis landscape, and please explain your perspective on this issue to the readers.

Avis Bulbulyan: This year has been a pivotal year for cannabis. The issues in cannabis aren’t linear and it’s not any one or two things to focus on.  In the creation of a robust industry like cannabis, there are many different fronts expanding at the same time. 

On the regulatory front, cannabis was deemed an essential business.  That means for all the industries that were shut down, cannabis was one of a handful allowed to stay open.  This has incredible implications, as it relates to policy reform at both state and federal levels.  

On the investment and public markets front, this year exposed almost all of the companies that along the way had lost focus on the consumer and started serving the investors.  

Currently, not much will happen with this election cycle but the toothpaste is out of the tube and the conversation of federal policy reform will be front and center over the next several years.  

Cannabis doesn’t just represent the financial markets.  The industry represents job creation and tax revenues.

Policy reform is probably the most effective and accurate tool for prison reform and has incredible social inclusion and justice implications.  

There are so many other industries and relevant conversations that cannabis intersects with that each could be a conversation on its own without it all being lumped together as a single cannabis industry issue and they’re not all exclusive.

Avis Bulbulyan of SIVA Enterprises (second from right)


In case of our current crisis, Cannabis has been deemed an essential service. In the June 2020 edition of cannabis Business Times, 34% of respondent consumers have been using more cannabis, and thus more cannabis, since the COVID-19  crisis began. 


CLR: With COVID-19, what has been the business impact so far? Are you doing anything new or differently? 

How have things evolved, specifically concerning Cannabis investing?

Avis Bulbulyan:  The sectors of the industry that benefited the most were the retailers followed by the suppliers. 

Beyond the plant touching companies, almost every other sector took a massive hit.  Coming out of this, as out as we can be at this point, the opportunities are starting to reveal themselves.

On the investment front, it’s either new opportunities, or old opportunities with a new set of glasses to view them through.

CLR: How do authenticity and consumer trust factor into your current course(s) of action?

Avis Bulbulyan:

The consumers are smart.

Smarter than most people give them credit for. 

If you’re not authentic with your brand, you won’t be able to build any sort of brand loyalty or brand equity with the consumer.

In the advanced tech and communication environment we live in today, people talk and you’re going to hear about the bad experience a consumer had with your product along with everyone else that consumer can reach through social media.

CLR: This is an industry that has grown primarily off consumer demand and consumer results.

What consumer demand do you currently see trending? What consumer behaviors or shifts? 

Avis Bulbulyan: The industry isn’t mature enough specific consumer trends to develop yet. 

Yes this industry has long had a very specific consumer base, but with the product offerings available and the expanded consumer base through state legalization, it’s really more about consumer education on what’s available to them as opposed to pitching any one product to them.

The average consumer just doesn’t know what’s available or on the market. 

Layer that with the patch work regulations at the state level, the product offerings available in one market aren’t available in other markets.

CLR: How did you earn your reputation of trustworthiness? Of market prediction and trajectory?

Avis Bulbulyan: One state and project at a time.

I always say that my reputation is worth more to me than any one project or any one retainer. 

My reputation was built on the work I did and every successful project led to more projects and higher level projects.

I never ask a client to do something I wouldn’t do myself and I never ask an investor to invest in something I wouldn’t put up my own money for.

I’ve been fortunate to work in a lot of very different markets across the country and from the beginning in those states. 

That’s allowed me to see how the different sectors and the different states roll out their programs. 

You get to see what works and what doesn’t. You get to see first hand the evolution of the different state markets, who the players are, the business models that work and those that don’t.

All that makes me more effective and valuable to the clients I serve.

CLR: How do you pick your top investment choices? Criteria?

Avis Bulbulyan:


Everyone has the best grower in the world.

Every pitch deck has the rosiest of projections.  It almost always comes down to the team.

There are only so many ways you can grow cannabis. Every square foot can only produce so much cannabis.

It’s the team that makes or breaks the company.

CLR: What specific areas of the Cannabis sphere do you view as having the most potential for growth and investment —edibles, cultivation, flower, individual States, to give some examples, but choose what YOU perceive and please expand. 

Avis Bulbulyan: Manufactured products by far. 

At some point, flower is just a commodity so cultivation is a race to the bottom.  With manufactured products, the best way to think about it is that anything you can consume, you can infuse, go figure out what the customer wants to consume.  

As a manufacturer, you have different revenue models available.  You can be a manufacturer for your own products or be a contract manufacturer for others. 

Be a co-packer for others.  You worry about manufacturing and let the brands worry about building their brands. 

CLR: What steps do you currently take to achieve and maintain your own premium reputation —and the reputation of SIVA Enterprises?

Avis Bulbulyan: The work and projects I take.  The companies I associate myself with.

For state licensing in any given state, I’ll probably field anywhere from 10-30 different groups but will only choose 1 or 2 groups to work with in any given state. 

The clients spend a lot of money on these projects.  If I don’t have the confidence that your group is going to be competitive or that I can add value to your group, I won’t take your money.

Almost every project I’ve had, by the time we were done, the client became like family.  

CLR: Please tell me about how SIVA specifically maintains transparency beyond regulations, both internally and externally.

Avis BulbulyanWe get offered equity positions by the majority of our clients.

We get offered management contracts long before the client needs one.  I don’t take them up on it because they don’t know what they’re giving up at that point in the relationship.

What I tell them is that I’m already getting paid to do what I do and what they don’t know today, they’ll know tomorrow.  Wait until tomorrow comes.

If you still want us to manage your project, or come in as an equity partner, we can always have that conversation at a later time when that time comes.

Not too many companies do that and will tie up clients in contracts long before those services are even needed.

Or if we have a client submitting an application in any given jurisdiction, SIVA will bow out and not submit a competing app.  

CLR: Explain basic Cannabis investing to the readers and consumers.

Avis Bulbulyan: No different than any other traditional investment. 

You just happen to be dealing with a product that’s a Schedule 1 drug at the federal level, so you need to be mindful of the limitations and restrictions. 

Beyond that, the cannabis industry isn’t just one industry.  It has sectors that are no different than traditional industries.

Manufacturing, retail, distribution, etc. The product just so happens to be cannabis.    

CLR: What is your foremost current goal at SIVA Enterprises?

Avis Bulbulyan: We’re restructuring as a holding company and about to launch a funding arm so we can fund client projects, so finishing out the year, the goal is to have this completed.

Current and long term, maintain and build on our reputation.

CLR: Generally speaking, what is the biggest challenge in Cannabis investment?

Avis Bulbulyan: Managing egos and expectations. 

Everyone from the operators to the investors have certain expectations.

Tapering and managing the expectations can’t be done without managing the egos that come with it.  

CLR: Something people don’t realize about Cannabis investing in a federally illegal — state legal divided country? Anything especially difficult?

Avis Bulbulyan: Banking. 

For owner operators, it’s one thing.  For companies that have investors, it’s another thing.

With limited banking options, payments and distributions become more difficult.

Layer tax issues that come with 280e, and sometimes it turns into a nightmare.

CLR: Tell me about and explain the process and reasons for M & A, or Mergers & Acquisitions?

Avis Bulbulyan: For reasons, there are a bunch. Companies not delivering on what they promised and now they’re neck deep in liabilities. 

Consolidation across sectors that complement each business. 

Operator fatigue which is a big one we’re seeing, where operators are just plain tired and want out. 

And sometimes you get companies –like we saw with MedMen— where they have access to capital and don’t understand how to utilize it so they go on buying sprees paying ridiculous amounts for companies so it makes sense for the smaller guy to sell.  

As for the process, it’s all over the place.  You’ll see everything from shotgun marriages to drawn out courtships that go on longer than needed.

The size of the deals also matter but it’s just a lot of due diligence.  

CLR: What are the biggest challenges that cannabis faces in the immediate future?

Avis Bulbulyan: Getting out of its own way.  You’re seeing a lot of situations where folks are sinking the ship just because they fell off.

Like any industry that starts from grass roots, you’re going to see a lot of changes in everything down to how business gets done.

Change scares a lot of folks and that leads to challenges.  

CLR: How do you envision the future of U.S. cannabis in the coming year, 2021? 

Avis Bulbulyan:

  • In 2021 you’ll see a tremendous amount of growth for the industry. 
  • You’ll see a lot of work going in to make a policy push in 2022. 


Politically, all change happens either in a presidential election year which we’re in now and missed, or a mid year like 2022. 

There won’t be much happening at the federal level next year, but you can absolutely be guaranteed we’ll see substantial movement in 2022.

CLR: In the next 3 years?

Avis Bulbulyan:

2021: Federal reform conversations will start getting and being taken more seriously. 

2022: We’ll see some meaningful federal policy up for consideration.

By 2024: I believe we’ll have federal reform and that’s when the flood gates open.

CLR: How do you envision the courts managing cannabis (investing, et al) —state vs federal? 

Avis Bulbulyan:  You’ll see much more activity in the courts with cannabis companies. There’s a misconception that federal court remedies are not available to cannabis companies and that’s not true.  

My own company filed a federal case against 5 defendants in federal court and when the defendants filed a motion to dismiss based on cannabis being a schedule 1 drug, the court sided with us. 

There have been contract disputes, and trademark disputes argued in district court.  That’s just going to expand even more.

 CLR: What do you see in the Cannabis landscape that needs to be improved, perfected, or achieved in the future?

Avis Bulbulyan: To a large degree, the industry needs to be left to evolve on its own without overburden it with regulations.

Most don’t realize that regulations don’t favor the small guy.  It’s the bigger more capitalized companies that can deal with regulations. 

Whatever regulations are developed, there have been enough states to have done this where we can focus on some uniformity now.

CLR: How do we get from here? 

Avis Bulbulyan: Keep pushing forward and not forget how we got here from the grass roots

CLR: What one thing you do in your line of work that you feel makes the most impact? Why does this make the most impact? 

Avis Bulbulyan: The policy work we’re able to do.

I serve on the state advisory board in CA that advises the 3 state agencies on CA’s regulations. 

I try to draw from my experience across the different markets and different sectors and try to provide the most honest input I can regardless of how it benefits my company specifically.

Personally, I try to bring a balanced approach and look at any one issue from the viewpoint of the different sectors.

For me, good public policy is first.  Business opportunities and opportunities to make money will always be there regardless of the regulations so that’s always secondary for me. 

CLR: What is the best advice you can offer to other individuals wanting to invest in the current U.S. Cannabis space? To companies?

Avis Bulbulyan:  Take your time.  You haven’t missed out on anything.  Learn from the mistakes already made.  Vet the teams.  Take a traditional approach to it. 

What I try to explain to folks is that the license itself is not and cannot be your business. 

All a license does is it authorizes an activity.  To make the most of your license, you first need a business model.  Then go back and see  if you even need a license.  

CLR: Anything you want to leave on the minds of our readers?

Avis Bulbulyan: We really have an opportunity with this industry to do a lot of good in this world. 

Think about how you can have a role in change and how you can participate in a meaningful way regardless of how you choose to participate. 


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