2026 Federal Hemp Ban: What It Means for Your BSA Program

Prepare your institution for the 2026 federal hemp law changes by understanding the BSA compliance, risk assessment, and customer due diligence implications of serving hemp-related businesses.

On November 12, 2025, President Trump signed the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act, 2026 (P. L. 119-37) (“the Act”). Section 781 of Division B of the Act materially amends the statutory definition of hemp under 7 U.S.C. §1639o and, absent intervening legislation, will render the vast majority of hemp-derived cannabinoid products currently on the market federally unlawful as of November 12, 2026. If your accountholders sell federally illegal products that are legal in your state, does that change your risk assessments and controls for BSA?

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