cbd food drink supplement

2021: The Year Hemp-Derived Foods and Dietary Supplements Become Lawful… Maybe.

It has been well over two years since Congress enacted the Agriculture Improvement Act of 2018 (the 2018 Farm Bill), which legalized the commercial production of hemp and tasked the Food and Drug Administration (the FDA) with the regulation of hemp-derived products intended for human consumption. Nevertheless, the FDA has yet to carve a legitimate

Spain Medical Cannabis

Spain Moves Toward Medical Cannabis Regulation

On May 13, the health committee of Spain’s Congress of Deputies approved a proposal to create a subcommittee that will consider other countries’ experiences with medical cannabis. The subcommittee’s findings could pave the way for medical cannabis legalization in Spain. According to a recent poll, approximately 90% of Spaniards would favor such a move. Spain

ketmaine clinic compliance

Ketamine Clinics and Compliance Plans

In prior posts, we discussed some of the common due diligence and compliance issues for ketamine clinics (see here and here). In this post, we discuss a healthcare compliance plan and the importance of having one in place for ketamine clinics. The Department of Health and Human Services (“HHS”) (which houses, among other agencies, the

mso cannabis marijuana

Cannabis Multi-State Operators: Top 5 Mistakes

We work with a good number of multi-state operator (MSO) cannabis companies. Always have. Most of these companies are publicly traded, although others remain closely held. With more MSOs on the scene than ever before, it seems like a good time to list out some pitfalls for MSOs, their decisionmakers, lenders, etc., as these companies

ketamine off label use

Ketamine and Off-Label Issues

A common question that arises in Ketamine clinic transactions is whether a clinic or physician (collectively, “healthcare providers” or “providers”) can use or promote Ketamine for off-label uses. The short answer is yes, subject to several caveats, as discussed below. However, before reaching the answer, it is important to define what “off-label” use means and

cannabis writ of attachment judgment litigation

Cannabis Litigation: Writs of Attachment

Last month, I wrote this post about the availability of fraudulent transfer claims under the Uniform Voidable Transactions Act when it’s possible that a cannabis judgment debtor (or soon to be judgment debtor) begins to move its assets around to avoid future payment. But what if you have those concerns at or near the beginning

delta 8 thc ban dea

R.I.P. Delta-8 THC

Delta-8 THC had a good run. People made money, customers were happy, and it all seemed legal to boot. Like all good things in life, states and the DEA are doing everything in their power to ensure that delta-8’s run comes to an end. Let’s talk about why. For those of you who may not