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The Philippines: Cannabis in Duterte’s Backyard?

For those of you familiar with the Philippines, you know that “President Rodrigo Duterte” and “war on drugs” are two parts of the same phrase. In the first two years of his presidency, Duterte sanctioned the killing of over 10,000 Filipinos who were connected in any way to the drug trade. But you might be

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FDA Guidance on Cannabis Research: A Glimpse of What’s To Come for CBD Products?

On Tuesday, July 21, the Food and Drug Administration (“FDA”) released draft guidance for clinical research related to the development and manufacturing of cannabis-based drugs, which gained particular interest following the legalization of hemp in December 2018. Although the guidance does not cover other FDA-regulated  products, such as hemp-derived CBD (“Hemp CBD”)-infused foods and dietary

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Indiana Set the Standard for Hemp CBD Labeling, But Misses the Mark on Smokable Hemp

Indiana has long been at the forefront of hemp product regulations. Two years ago in 2018, Indiana passed a comprehensive law that regulated “low-THC hemp extracts.” At the time, state-level regulation of CBD was mostly limited to medical marijuana programs in conservative states that only allowed CBD extracts for use by medical patients. Very few

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Indiana Smokable Hemp Ban is Upheld (For Now)

The Agriculture Improvement Act of 2018 (“2018 Farm Bill”) legalized hemp by removing hemp and its derivatives from the definition of marijuana under the Controlled Substances Act (“CSA”). The 2018 Farm Bill also provided a detailed framework for the production of hemp and directed the U.S. Department of Agriculture (“USDA”) to promulgate regulations and permitted

CBN

Is CBN a Controlled Substance? Yes. No. Maybe.

Earlier this year, we discussed the legality of lesser-known hemp-derived cannabinoids which appeared to be gaining success in the U.S. One of these promising cannabinoids is cannabinol (“CBN”). Put simply, CBN is a non-intoxicating cannabinoid that results from the degradation of THC. Because it is difficult, if not impossible, to grow CBN-rich strains of hemp,

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The Latest Report from the FDA Shows How Poorly It Has Handled CBD

On Wednesday, July 8, the Food and Drug Administration (FDA) sent Congress a report on the CBD marketplace. Last year, Congress mandated that the FDA report on hemp-derived CBD in appropriations legislation. You can find the report linked at the bottom of this article from Marijuana Moment, which also provides an overview of the report.

New FinCEN Hemp Banking Guidance

ICYMI: The New FinCEN Hemp Banking Guidance

Last week, the Financial Crimes Enforcement Network (FinCEN), issued new guidance (the “FinCEN Guidance”) for financial institutions working with hemp-related businesses. The FinCEN Guidance centers on due diligence requirements as related to the Bank Secrecy Act (BSA). This guidance follows closely on the new National Credit Union Administration (NCUA) guidance for federally-chartered credit unions, which

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Hemp CBD Across State Lines: What You Need to Know

The Agriculture Improvement Act of 2018 (2018 Farm Bill) legalized hemp by removing the crop and its derivatives from the definition of marijuana under the Controlled Substances Act (CSA) and by providing a detailed framework for the cultivation of hemp. The 2018 Farm Bill gives the US Department of Agriculture (USDA) regulatory authority over hemp

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Credit Unions and Hemp: New Federal Guidance is Here!

Last week, the National Credit Union Administration (NCUA) issued new guidance (“Guidance”) for federally-chartered credit unions serving the hemp industry. All of us at Harris Sliwoski were excited to see the Guidance released: NCUA retained us last fall to advise the government on this project, and we have always represented credit union clients as to

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Hemp CBD Across State Lines: Wyoming

The Agriculture Improvement Act of 2018 (2018 Farm Bill) legalized hemp by removing the crop and its derivatives from the definition of marijuana under the Controlled Substances Act (CSA) and by providing a detailed framework for the cultivation of hemp. The 2018 Farm Bill gives the US Department of Agriculture (USDA) regulatory authority over hemp

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