Photo of Aaron P. Kouhoupt

Aaron Kouhoupt offers a unique perspective shaped by more than 15 years’ experience as both in-house and outside counsel to banks, FinTechs, and other financial institutions of various sizes and formats. He serves as the firm's Chief Privacy Officer, and has authored content related to banking developments in the cannabis space.

On May 16, 2024, the U.S. Drug Enforcement Administration (DEA) released the proposed rule (Proposed Rule) to reschedule marijuana from Schedule I to Schedule III under the Controlled Substances Act (CSA). The Office of Legal Counsel (OLC) also provided a memo to the Department of Justice (DOJ) supporting the DOJ, which oversees the DEA and grants the DEA authority to make rules under the CSA to the DEA.
Continue Reading Rescheduling Marijuana FAQs: How Do I Submit Comments on DEA’s Proposed Rules?

In late August, the U.S. Department of Health and Human Services announced that it would recommend moving marijuana from Schedule I to Schedule III of the Controlled Substances Act. In this episode, corporate cannabis attorney Daniel Shortt moderates a discussion with tax attorney Douglas Charnas and financial services regulatory attorney

Continue Reading Podcast: Tax and Banking Implications of Rescheduling Marijuana

The Conference of State Bank Supervisors (CSBS) has sent letters to the U.S. House of Representatives and the Senate, stressing the importance of providing safe harbor for financial institutions offering financial products and services to cannabis or cannabis ancillary businesses under the proposed Secure and Fair Enforcement (SAFE) Banking Act.
Continue Reading Will the Push for a Bank Safe Harbor on Cannabis Succeed?