Harris Sliwoski LLP 的作者 Jack Scrantom https://harris-sliwoski.com/blog/author/jack-scrantom/ 艰难的市场,大胆的律师 Thu, 14 Mar 2024 16:11:28 +0000 en-US 每小时 1 https://wordpress.org/?v=6.4.3 https://harris-sliwoski.com/wp-content/uploads/cropped-Harris-Sliwoski-Logo-FinalIcon-White-1-32x32.png Harris Sliwoski LLP 的作者 Jack Scrantom https://harris-sliwoski.com/blog/author/jack-scrantom/ 32 32 华盛顿州发布关于SB 5367(含四氢大麻酚产品)的规则指南 https://harris-sliwoski.com/cannalawblog/washington-releases-rules-guidance-on-sb-5367-products-containing-thc/ Tue, 18 Jul 2023 14:00:37 +0000 https://harris-sliwoski.com/?post_type=cannalawblog&p=131926 The Washington State Liquor and Cannabis Board (WSLCB) released a rules guide on July 14, “outlining regulations of products containing THC”. The guide is titled “Discontinued Sales of Products Containing THC by Businesses that Do Not Hold a Cannabis License” and it relates to recently enacted SB 5367, which we’ve been following closely. As we

The post Washington Releases Rules Guidance on SB 5367 (Products Containing THC) appeared first on Harris Sliwoski LLP.

]]>
The Washington State Liquor and Cannabis Board (WSLCB) released a rules guide on July 14, “outlining regulations of products containing THC”. The guide is titled “Discontinued Sales of Products Containing THC by Businesses that Do Not Hold a Cannabis License” and it relates to recently enacted SB 5367, which we’ve been following closely.

As we explained here, SB 5367 redefined “cannabis product” to include products with any detectable amount of THC. This is a significant departure from the status quo that allowed ordinary retailers without a WSLCB licensed cannabis retail license (e.g. convenience stores, online sellers) to sell products that contained 0.3% or less THC. A large number of these products — mostly hemp-derived CBD products — are currently on shelves in stores without cannabis licenses all over the state.

SB 5367 is effective July 23 and there were serious open questions from the bill that needed to be answered. Some of them now have been…kind of.

Licensure required to “manufacture, sell, and distribute” products with THC content, or else

We already had confirmation from the WSLCB that products containing 0.3% or less THC are now going to be considered cannabis products and only available for sale by licensed cannabis businesses. The rules guide confirms this, and states that selling these products without a license is subject to criminal sanctions.

The rules guide is silent about when the WSLCB is going to be enforcing this new law—the effective date of July 23 or after the rulemaking is complete early next year. It is ridiculous that the WSLCB did not include a statement in the guide answering that question. What are businesses supposed to think? Is the WSLCB going to go around arresting or citing store owners writ large on the 23rd who still have these CBD products on their shelves? I work hard to avoid alarmist interpretations of new regulations, but the WSLCB is putting businesses in a position of having no choice but to plan for and expect the worst.

The rules guide goes on to state that “Only those with a valid cannabis license issued by the Liquor and Cannabis Board may manufacture, sell, or distribute … cannabis-infused products.”. The rules guide also provides that “cannabis-infused products include any product with any detectable amount of THC intended to be: consumed, absorbed inside the body by any means including: inhalation, ingestion, insertion.” There you have it: all products (except CHABA’s, see below) with any THC content (yes, including federally legal THC content under the Farm Bill) are cannabis infused products under Washington law. That means businesses that are manufacturing, selling, or distributing them must have a WSLCB cannabis license.

Cannabis Health and Beauty Aid (CHABA) products are exempt from SB 5367. These are topical products not meant for human consumption like CBD gummies, joints, tinctures, etc., and FDA has taken the position that these products may be kosher. The guide also makes clear that FDA approved products like hemp seed, hemp seed oil, etc. are exempt.

Uncertain times ahead for Washington hemp and CBD product sales

The WSLCB’s interpretation of SB 5267 is a massive regulatory shift for the Washington cannabis and CBD industries. Retail businesses without cannabis licensure should insist that the WSLCB provide clarity on an effective date for enforcement and whether there will be a grace period for violations. Whether that date is next week or next year, this is a good time to revisit contracts and consider issues like contract termination, breach, and defenses.

CBD producers will likewise be in a bind if they are currently producing products with federally legal amounts of THC. My guess is there will be a good deal of M&A and other business transactions between cannabis businesses and CBD businesses. The practicality and expense of making an operation compliant with this law — as compared to selling or partnering with licensed operators — will appeal to some. This guidance is a worst-case scenario for many businesses in the Washington CBD space and from what I’m hearing has caught many by surprise.

We’ll continue to monitor developments related to SB 5267 and Washington’s regulation of products that contain THC.

Need Help With Washington Cannabis Law?

Contact Us

The post Washington Releases Rules Guidance on SB 5367 (Products Containing THC) appeared first on Harris Sliwoski LLP.

]]>
华盛顿州大麻DDE污染问题暂时得到解决 https://harris-sliwoski.com/cannalawblog/washingtons-cannabis-dde-contamination-issue-resolved-for-now/ Wed, 12 Jul 2023 14:00:04 +0000 https://harris-sliwoski.com/?post_type=cannalawblog&p=131777 The Washington State Liquor and Cannabis Board (WSLCB) issued a bulletin Monday, July 7 stating that its enforcement efforts related to the April DDE contamination alert had been wrapped up. Earlier this year, in April, a slew of Okanogan county licensees’ cannabis products tested “hot” during the Washington Department of Agriculture’s (WSDA) random testing for

The post Washington’s Cannabis DDE Contamination Issue Resolved, For Now appeared first on Harris Sliwoski LLP.

]]>
The Washington State Liquor and Cannabis Board (WSLCB) issued a bulletin Monday, July 7 stating that its enforcement efforts related to the April DDE contamination alert had been wrapped up. Earlier this year, in April, a slew of Okanogan county licensees’ cannabis products tested “hot” during the Washington Department of Agriculture’s (WSDA) random testing for dichlorodiphenyldichloroethylene (“DDE”). DDE is a derivative chemical that forms following the breakdown of the infamous “DDT” (dichlorodiphenyltrichloroethane) that was widely used in the U.S. as a pesticide until it was banned in 1972.

Pesticide testing results

Initially, the WSLCB placed administrative holds on 18 licensees and performed additional testing on their cannabis products as well as on soil and water in the area. Ultimately, five licensees had administrative holds remaining on their licenses, which have now been removed. According to the WSLCB, further testing resulted in 61 of 108 products testing positive for DDE above the action limits. Those products have been identified, holds placed on them, and the WSLCB will work with the licensees to destroy them. If you are interested in the state’s interactive map showing pesticide testing results, it’s here.

Pesticide and heavy metals testing regime for cannabis

Washington enacted a pesticide and heavy metals testing regime for cannabis in March of 2022. The pesticide action level rule lists 59 allowable pesticide compounds and their acceptable thresholds that cannabis products must be screened for before they can be sold. DDT and its derivative DDE are not on the list of compounds that are screened for. The WSLCB acknowledged this in its alert that “state-certified cannabis-testing labs are not required to screen for DDE among the 59 pesticides included in mandatory testing because DDE contamination above actionable levels has not emerged elsewhere”.

When I wrote about this at the time, I criticized the state for not having placed DDT/DDE on the list of 59 compounds which all cannabis products are screened for. That may seem like Monday morning quarterbacking, but I found it justified because of the widespread historic usage of DDT in Washington. The compound’s extended half-life gives it a propensity to sit latent in soil and reemerge years after use makes that particularly true.

As mentioned above, the WSDA was responsible for catching the DDE contamination, not a certified lab. That’s because the mandatory screening procedure for all cannabis doesn’t include DDT/DDE testing. The WSLCB has not said whether DDT/DDE will be added to the mandatory chemical screening. From the tone of the WSLCB’s bulletin, it sounds like certified testing labs in the state just don’t have the equipment to test for DDT/DDE contamination. Adding it to the list may be out of the question at this time. We know that there is a scarcity of testing labs in the state that are equipped to handle mandatory testing as it is.

That is cause for concern. As it stands now, the WSDA may be the only agency capable of testing cannabis for DDE and the use of DDT in the state was not limited to Okanogan county. It seems like a similar situation involving DDE or another legacy contaminant could surely happen and go unnoticed after the product is on the market. It would be nice to know that all cannabis products were being screened appropriately for contaminants, instead of hoping the WSDA catches it before too many people use contaminated cannabis. Issues like this are almost impossible to avoid entirely, but catching the problem early through mandatory screening seems like the only practical solution.

I stand by my earlier criticism, but the WSLCB deserves some credit for doing its best here. Mounting an effort to test all of the potentially contaminated cannabis, soil, and water as necessary to ensure consumer safety was no small task. The fact that initial results seem to have resulted in 2/3 of the licensees’ administrative holds being removed fairly quickly and all remaining administrative holds now being lifted, is impressive. Most importantly, it doesn’t sound like anyone was seriously injured and the WSLCB appears to have done a good job of mitigating any damage.

Need Help With Washington Cannabis Law?

Contact Us

The post Washington’s Cannabis DDE Contamination Issue Resolved, For Now appeared first on Harris Sliwoski LLP.

]]>
华盛顿州颠覆其CBD产业 https://harris-sliwoski.com/cannalawblog/washington-upends-its-cbd-industry/ Tue, 20 Jun 2023 14:00:13 +0000 https://harris-sliwoski.com/?post_type=cannalawblog&p=131417 Last month, Washington governor Jay Inslee signed SB 5367, a largely unpublicized bill “concerning the regulation of products containing THC”. Among other things, the bill amends the definition of “cannabis product” in the state’s Controlled Substances Act to include products with any detectable amount of THC concentration. Selling such CBD products will require licensure by

The post Washington Upends Its CBD Industry appeared first on Harris Sliwoski LLP.

]]>
Last month, Washington governor Jay Inslee signed SB 5367, a largely unpublicized bill “concerning the regulation of products containing THC”. Among other things, the bill amends the definition of “cannabis product” in the state’s Controlled Substances Act to include products with any detectable amount of THC concentration.

Selling such CBD products will require licensure by the Washington State Liquor and Cannabis Board (WSLCB), effective July 23, 2023. The WSLCB is set to vote on initiating the rulemaking process under the state’s administrative procedures act on July 21. Although rulemaking won’t commence for a month, any business manufacturing or distributing CBD products for sale in the state Washington should begin to prepare for this sea change today.

What does SB 5367 do?

The bill amends the definition of a cannabis product in Revised Code of Washington (RCW) 69.50.101 to include “any product intended to be consumed or absorbed inside the body by any means including inhalation, ingestion, or insertion, with any detectable amount of THC” (my emphasis). The former definition of a cannabis product meant “useable cannabis, cannabis concentrates, and cannabis-infused products”. Clearly excluded from that definition were CBD products with a THC concentration of less than 0.3%, as that threshold was the defining characteristic of cannabis under state and federal law.

The bill also adds the defined term “hemp consumable” to RCW 15.140.020, which means:

“a product that is sold or provided to another person that is: (a) made of hemp; (b) not a cannabis product as defined in RCW 69.50.101; and (c) Intended to be consumed or absorbed inside the body by any means, including inhalation, ingestion, or insertion.”

This added definition clarifies that a hemp consumable, be it a smokable hemp joint, CBD tincture, etc. may not have any THC in it whatsoever.

Also important, is that the bill changed the definition of “THC concentration.” The new definition no longer references delta-9 THC. There are several types of THC in cannabis plants, delta-9 being the most commonly known because it is the most prevalent and intoxicating form of THC. The removal of delta-9 from the definition of THC content is important because it broadens the criteria for a product being considered a cannabis product.

The conclusion of the federal regulators and agencies, as evidenced by the Farm Bill, is that products containing less than 0.3% delta-9 THC are incapable of producing intoxicating effects. So, the insistence by Washington lawmakers that hemp-derived CBD products contain 0.0% of any THC isomer doesn’t read like a public health initiative. Rather, it seems like the cannabis lobby successfully using the lawmaking process to recapture a significant part of the CBD industry. This is made pretty clear when we consider that one of the open questions is whether the production of CBD products containing over 0.0% THC will now require a WSLCB cannabis producer license.

Consequences of WSLCB regulating all Washington CBD commerce

For years, large sectors of the U.S. CBD industry have been producing CBD products in line with the 2018 Farm Bill (“Farm Bill”). The Farm Bill made the production and sale of hemp and hemp derived products federally legal, so long as they contain less than 0.3% delta-9 THC. Most states have deferred to the feds (outside of the FDA context) and the U.S. CBD products market has since grown into a multi-billion dollar per year industry doing $5.3 Billion in sales in 2021. That figure is projected to grow to $16 Billion in 2026.

CBD products are sold at many, many retail stores in Washington at the moment, from bodegas on Aurora to Wholefoods in Bellingham, and everywhere in between. The prevalence of CBD products in Washington retail stores raises a serious question for these retailers about how (and whether?) the WCLCB will enforce the law. In any case, Washington is showing itself to a be true outlier with SB 5367, by forcing these sales through its state cannabis regulator’s pipeline.

We should also note that there are processing methods that isolate only CBD from the hemp plant that exclude all THC and other cannabinoids. Producers of these CBD products, the retailers that buy these products for resale, and the consumers of them won’t be negatively affected by this bill. With that said, a lot of Farm Bill legal CBD products do have some detectable amount of THC in them. Those products will now be considered cannabis products in Washington. Subject to rulemaking and absent any further guidance on the matter, it seems like those products will only be available for sale in a WSLCB licensed retail cannabis dispensary.

The economic impacts of this bill are sure to be enormous. To highlight just a few:

  1. CBD producers of products containing federally legal amounts of THC in Washington will lose access to a much larger retail market: they will be forced to sell their products exclusively in WSLCB licensed cannabis dispensaries.
  2. E-commerce CBD sales account for 40% of the U.S. market and CBD producers from out of state will be faced with complicated compliance questions including whether selling online directly to consumers in Washington is legal anymore.
  3. Retailers without a WSLCB cannabis retail license are going to have to terminate supply contracts and liquidate existing inventory. Many will ultimately lose out on revenue from selling products previously considered lawful and not requiring special licensure.

WSLCB enforcement is an open question

We don’t yet know how the WSLCB is going to enforce this new law or whether it will wait pending completion of the rulemaking process. As noted above, the WSLCB is having a meeting on June 21 and a vote will be held to initiate a pre-proposal statement of inquiry (a “CR-101”). This is part of the rulemaking process under the state’s administrative procedures act that is necessary where bills signed into law by the governor require interpretation and specific rules on how an agency will be enforcing a new law.

The WSLCB needs to provide clarity on several open questions. If the state’s position is that both the production and sale of all products containing detectable levels of THC now requires a WSLCB cannabis license, SB 5367 will be a massive boon to the state cannabis industry. If a processor must chose between: a) changing its methods so a WSLCB license is not required, or b) partnering with WSLCB licensed producers and processors, many may chose the former.

Relate to this analysis, Washington has placed a moratorium on issuing new cannabis licenses; so it is not as if businesses thrown out of compliance by SB 5367 can merely apply for and obtain a cannabis license. Equally important, many CBD products with detectable levels of THC sit on shelves all over the state right now. The possibility of all of them being removed by July 23 seems remote at best. What are these retailers to do with that product if they cannot sell it before July 23? What will the penalties be for violations? Will there be a grace period of some sort? The state needs to provide guidance on these and other questions so that stakeholders can prepare themselves.

We’ll be following developments from the state on this emerging issue here.

Need Help With Washington Cannabis Law?

Contact Us

The post Washington Upends Its CBD Industry appeared first on Harris Sliwoski LLP.

]]>
华盛顿州的迷幻药法案正在等待州长的批准 https://harris-sliwoski.com/psychlawblog/washington-psilocybin-bill-awaits-governors-approval/ Tue, 25 Apr 2023 14:00:43 +0000 https://harris-sliwoski.com/?post_type=psychlawblog&p=130852 Washington’s House and Senate have both approved the “Washington Psilocybin Services Act” (SB 5263) and the bill awaits Governor Jay Inslee’s signature. Psilocybin is a schedule I drug under the federal Controlled Substances Act and is the psychoactive or “hallucinogenic” component of magic mushrooms. Washington appears set to follow in the footsteps of Oregon and

The post Washington Psilocybin Bill Awaits Governor’s Approval appeared first on Harris Sliwoski LLP.

]]>
Washington’s House and Senate have both approved the “Washington Psilocybin Services Act” (SB 5263) and the bill awaits Governor Jay Inslee’s signature. Psilocybin is a schedule I drug under the federal Controlled Substances Act and is the psychoactive or “hallucinogenic” component of magic mushrooms. Washington appears set to follow in the footsteps of Oregon and Colorado in breaking from federal law on psilocybin controls. However, SB 5263 arises from legislative action rather than a ballot measure vote, and it prescribes an incremental, more conservative approach than the Oregon or Colorado programs.

In recent years, as the original bill noted, psilocybin has emerged as a promising therapeutic treatment for people suffering from a range of mental health disorders that are treatment resistant. Examples include post-traumatic stress disorder, end-of life anxiety, and depression. The Washington legislature acknowledged some important therapeutic facts about the use of psilocybin by citing that the FDA has:

“(a) Determined that preliminary clinical evidence indicates that 2 psilocybin may demonstrate substantial improvement over available therapies for treatment-resistant depression; and

(b) Granted a breakthrough therapy designation for a treatment 5 that uses psilocybin as a therapy for such depression.”

I’d be remiss if I didn’t briefly note here that as a schedule I narcotic under the Controlled Substances Act, psilocybin is considered to have “no currently accepted medical use and a high potential for abuse.” That definition is clearly in conflict with the FDA findings cited by the WA legislature. But I digress. Still, the WA legislature’s acknowledgement of the FDA’s findings on the therapeutic use of psilocybin indicates that it is taking the point about the legitimacy of these treatments seriously.

The original Washington psilocybin bill

The original bill that was brought before WA legislators in January would have allowed adults over 21 years of age to use psilocybin under the supervision of licensed professionals “for wellness and personal growth”.  The original bill came in at around 80 pages, and would have created a system for regulation and use of psilocybin.

Among its provisions was a 2-year development program period ending in September, 2025 after which people over 21 would have access to psilocybin services at psilocybin service centers. It also required that by January 2, 2024, the state would begin receiving applications for licensing people to manufacture psilocybin products, operate a service center, facilitate psilocybin services, and test psilocybin products. Unfortunately, the approved bill at around 10 pages long, canned most of the progress contained in the original bill.

The approved Washington psilocybin bill

The approved bill removes most of text of the original bill, including its milestones and mandates. Instead, it replaces them with task forces, advisory boards, and a University of Washington Pilot Program, with no end date for rulemaking and fact finding.

The Pilot Program will offer psilocybin services to qualified individuals and must be operational at UW by January 1, 2025. By contrast, the original bill would have allowed private, licensed psilocybin service centers to administer psilocybin treatment by the end of 2025. Requiring merely a pilot program to be operated at UW by January 2025 means that the opening of licensed service centers is unlikely until well afterwards. The findings and clinical data from the UW pilot program is probably intended to inform rule creation and implementation and therefore will need to be reviewed by all of the administrative bodies put in place as part of that process.

Governor Jay Inslee’s policy advisor for public health stated in an email earlier this year that “[the original bill] is not supported by the available scientific and medical evidence”. The approved bill is without meaningful mandates regarding policy goals and prescribed timelines. The result of that is sure to be a more protracted lawmaking process in spite of the rather impressive work in the original bill. With all of that said, given the Governor’s policy advisor’s hesitation on the original bill, this version of the bill is more likely to be approved.

Two steps forward, one step back

The approved bill is almost certainly an acquiescence to the concerns of lawmakers more skeptical of drug use that is not endorsed from on high by the FDA, and that seems to include the Governor himself. In spite of the growing and promising body of clinical data emerging from “psycho-therapy” clinics on the efficacy of these treatments, there remains a significant cohort of lawmakers and voters who just don’t (and probably won’t) get it. The approved bill is a step in the right direction, but it is a significant step backwards from the text of the original bill. For those excited about the prospect of a Washington with licensed psilocybin service centers, the approved bill has pushed that reality back to an unknown future date.

We’ll be monitoring developments here, so stay tuned to the Psychedelics Law Blog.

The post Washington Psilocybin Bill Awaits Governor’s Approval appeared first on Harris Sliwoski LLP.

]]>
杀虫剂 "DDT "的衍生物在西澳的几种大麻产品中被发现 https://harris-sliwoski.com/cannalawblog/pesticide-ddt-derivative-found-in-several-wa-cannabis-products/ Mon, 10 Apr 2023 14:00:53 +0000 https://harris-sliwoski.com/?post_type=cannalawblog&p=130649 The Washington State Liquor and Cannabis Board (“WSLCB”) sent an alert on Thursday, April 6, notifying cannabis licensees of a pattern of pesticide testing failures in Okanogan County. The WSLCB detected several instances of products containing dichlorodiphenyldichloroethylene (“DDE”) through random pesticide testing and many exceed action levels. The WSLCB is taking the following immediate action

The post Pesticide “DDT” Derivative Found in Several WA Cannabis Products appeared first on Harris Sliwoski LLP.

]]>
The Washington State Liquor and Cannabis Board (“WSLCB”) sent an alert on Thursday, April 6, notifying cannabis licensees of a pattern of pesticide testing failures in Okanogan County. The WSLCB detected several instances of products containing dichlorodiphenyldichloroethylene (“DDE”) through random pesticide testing and many exceed action levels.

The WSLCB is taking the following immediate action to address the issue, which will specifically affect 18 licensees in Okanogan County:

  • “Placing administrative holds on licensees in the affected geographic area with above actionable limits of DDE;
  • Upon confirmation that DDE exists in the soil in this region, placing administrative holds on all licensees in the geographic area;
  • Requesting a list of all products distributed since August 2022 from all licensees in the geographic area;
  • Securing and testing on-shelf products from all 18 licensees in the geographical area; and
  • Requesting the licensees in the geographic area with DDE tests above actionable limits conduct a licensee-initiated recall on all products.”

What is DDE?

DDE is a derivative chemical that forms following the breakdown of the infamous “DDT” (dichlorodiphenyltrichloroethane) that was widely used in the U.S. as a pesticide until it was banned in 1972. According to the Centers for Disease Control, “Microorganisms in the soil slowly break down DDT (it can take anywhere from 2 to 15 years to break down half of the DDT)”.

The CDC states that risk for exposure is low and most exposures occur from eating contaminated foods. Further, people that swallow large amounts of the chemical had tremors, headaches, nausea, and seizures, though no effects were noticed when people took a small dose over the course of 18 months. People with higher levels of the chemical in their blood have an increased risk of liver cancer.

Both DDT and DDE are considered legacy contaminants–chemicals once used in the U.S. but then discontinued or made illegal under US law. Legacy contaminants often linger in soil and water long after they were initially used on the site or made their way to a particular site from another location. Legacy chemicals once used on a particular plot of land say, can “resuspend” years later and through soilborne drift, land on other properties. Similarly, soil and sediment lifecycles could result in latent legacy contaminants re-emerging and contaminating crops long after their initial use.

There seems to be ample evidence of DDT being widely used in Washington, particularly in orchards and vineyards on the eastern slope of the Cascades. According to a 2008 research paper investigating DDT and DDE levels in Lake Chelan, WA, “DDT was commonly used at Washington orchards from about 1946 to 1970, with high application rates (citation removed) being documented for eastern Washington orchards in the vicinity of Lake Chelan.” For reference, Omak, the largest city in Okanogan County, is around 60 miles from Lake Chelan.

How did the DDE exposure occur?

It appears that the producers in Okanogan County are dealing with the reemergence of pre-existing, latent DDT (now broken down to DDE) on their properties. As the WSLCB stated in its alert “The cannabis crop possesses a unique vulnerability with respect to environmental contamination. The plants can absorb contaminants such as pesticides and heavy metals to a much higher degree than many other plants.”

Pesticide testing of cannabis in Washington

As we wrote about here, Washington enacted a pesticide and heavy metals testing regime for cannabis in March of 2022. The pesticide action level rule lists 59 allowable pesticide compounds and their acceptable thresholds that cannabis products must be screened for before they can be sold. DDT and its derivative DDE are not contained on the list of compounds that are screened for. The WSLCB acknowledged this in its alert that “state-certified cannabis-testing labs are not required to screen for DDE among the 59 pesticides included in mandatory testing because DDE contamination above actionable levels has not emerged elsewhere”.

So how did the state catch the DDE in the cannabis products in this case? The state has been conducting random testing of cannabis products for several years. But the screening that randomly selected products are subject to is considerably more comprehensive than the mandatory testing all cannabis products must be tested for under Washington Annotated Code section 314-55-109. The LCB stated in its alert that it “contracts with the state Dept. of Agriculture (WSDA) … to perform pesticide tests. The WSDA lab can currently detect 243 pesticides. Their testing includes DDT and its breakdown products such as DDE.”

This begs the question of why DDT and DDE are contained in the WSDA screening procedures and not the mandatory pesticide screening procedures under WAC 314-55-109, particularly when the WSLCB acknowledged that cannabis plants are uniquely vulnerable to such contamination. The answer probably lies in not having the resources to subject all cannabis product testing to the more comprehensive WSDA testing procedures. Nonetheless, given the well-known and widespread use of DDT in Washington, it seems like DDT and DDE at least deserved to make the cut given their latent and reemergent characteristics.

Outcome

The 18 licensees within the “affected area” are going to have a tough time surviving the administrative action being taken by the state. It seems probable given the historically widespread use of DDT in the region that at least some of the soil samples the WSLCB plan to take will come back contaminated. The result of that will be administrative holds for all 18 licensees. What happens thereafter is unclear.

Further, all licensees products will be tested for DDE contamination and for those that have a product fail, a recall of all of their products will be required. I’m not suggesting that this action shouldn’t be taken. No one wants to consume contaminated cannabis products. But the fact remains that this administrative action is going to be devastating.

If your outdoor grow operation is in historically orchard and vineyard country, this issue may affect you. We don’t know at this time what the state’s regulatory response will be but the chances of it being nominal are slim. The prevalence of DDT use in the state may mandate a regulatory response affecting cannabis testing in the entire state.

We’ll be following developments here.

Need Help With Washington Cannabis Law?

Contact Us

The post Pesticide “DDT” Derivative Found in Several WA Cannabis Products appeared first on Harris Sliwoski LLP.

]]>
华盛顿州的社会公平大麻许可证申请窗口延长 https://harris-sliwoski.com/cannalawblog/washingtons-social-equity-in-cannabis-license-application-window-extended/ Fri, 31 Mar 2023 14:00:46 +0000 https://harris-sliwoski.com/?post_type=cannalawblog&p=130522 The Washington State Liquor and Cannabis Board (WSLCB) voted on Wednesday, March 29, approving an emergency rule proposal to extend the application window for social equity in cannabis (SEIC) retail licenses. The application window has been extended from March 30, 2023, to 5:00 p.m. April 27, 2023. The rule will have the effect of amending

The post Washington’s Social Equity in Cannabis License Application Window Extended appeared first on Harris Sliwoski LLP.

]]>
The Washington State Liquor and Cannabis Board (WSLCB) voted on Wednesday, March 29, approving an emergency rule proposal to extend the application window for social equity in cannabis (SEIC) retail licenses. The application window has been extended from March 30, 2023, to 5:00 p.m. April 27, 2023. The rule will have the effect of amending the “30-day” application window language contained in WAC 314-55-570(3)(a), (b), and (c).

The WSLCB said in its release announcing the vote last week, that the Secretary of State’s office is backlogged processing business entity applications. The backlogs have limited the state’s ability to timely process new business entity applications of SEIC applicants.

This is sure to be a relief for many who have made timely efforts to apply for the SEIC license, and who would not have been able to apply with the prerequisite business entity information but for the state’s backlog issues. Hopefully, the extended window affords enough time for all deserving candidates to apply.

To read more about Washington’s SEIC program, check out the following posts:

 

Need Help With Washington Cannabis Law?

Contact Us

The post Washington’s Social Equity in Cannabis License Application Window Extended appeared first on Harris Sliwoski LLP.

]]>
大麻企业是否允许进行504次私募证券发行? https://harris-sliwoski.com/cannalawblog/are-504-private-placement-security-offerings-allowed-in-cannabis-businesses/ Mon, 20 Mar 2023 14:00:37 +0000 https://harris-sliwoski.com/?post_type=cannalawblog&p=130221 We’ve written regularly about the plight of cannabis businesses not being able to secure traditional lending (and other financial services) from major, federally regulated institutions. In this post, we dive deeper into a promising federally regulated equity offering as an alternative funding means: Rule 504 under Securities and Exchange Commission (“SEC”) Regulation D. Why aren’t

The post Are 504 Private Placement Security Offerings Allowed in Cannabis Businesses? appeared first on Harris Sliwoski LLP.

]]>
We’ve written regularly about the plight of cannabis businesses not being able to secure traditional lending (and other financial services) from major, federally regulated institutions. In this post, we dive deeper into a promising federally regulated equity offering as an alternative funding means: Rule 504 under Securities and Exchange Commission (“SEC”) Regulation D.

Why aren’t banks more involved?

Despite adoption by a growing number of states, marijuana is (still) federally illegal. Federal laws preventing money laundering and other financial crimes create regulatory hurdles so significant for most major banks to service cannabis businesses that it just isn’t worth the compliance burden.

While state-regulated credit unions have stepped up to fill some of the void, institutional lending remains largely unattainable. The remainder of the void is filled by private lenders from the private equity and venture capital crowd and individual investors that require often significant collateral and interest rates that reflect the ongoing marijuana industry risk.

Raising money through private placements

When a cannabis company wants to raise capital through a private placement (sale) of securities, it subjects itself to federal and potentially state securities laws, regardless of whether they are raising through debt, equity, convertible debt, or something more creative like a SAFE (simple agreement for future equity).

What is a security or investment contract? Howey tells us

All private capital raises implicate securities laws. The definition of a security, while complex and fact-specific, in the private capital raise context is most clearly captured by the infamous U.S. Supreme Court case SEC v. Howey Co.

In Howey, the Court held that the catch-all term “investment contract” as used in the Securities Act’s definition of a security includes any contract or scheme where there is: 1) an investment of money; 2) in a common enterprise; 3) with the expectation of profit; 4) to be derived primarily from the efforts of others. Thus, the passive investment of capital into a cannabis business with the expectation of a return based on the success of the cannabis business is a security.

Under the federal securities laws, a company (the “issuer”) may not offer or sell securities unless the offering has been registered with the SEC or an exemption from registration is available. If they can, issuers typically prefer to avoid registration of securities offerings because it’s a lot of work and highly expensive. So, how can a cannabis company offer exempt securities to raise capital?

How does a Rule 504 exempt offering work?

Offerings may be exempt from the SEC’s registration requirements pursuant to Securities Act Section 4(a)(2) or its safe harbor under Regulation D of the Securities Act. Reg D includes Rule 504 that offerors commonly use to use securities without registration. This exemption sits nicely between the traditional Reg A+ public offering and Reg CF crowdfunding offering.

At the risk of oversimplifying, Rule 504 allows for the sale of up to $10MM in securities to non-accredited investors, but the issuer cannot advertise the offering publicly (this is called “general solicitation”). Accredited investors can still be involved and generally do not count against any investor limitations. Accredited investors, generally, have at least $1 million in net worth or income over $200,000 (individually) or $300,000 (with spouse or partner) in each of the prior two years.

For most smaller cannabis companies trying to raise capital, their capital needs are often too small for accredited investors to be interested in or do not have access to accredited investors in the first place. Thus, Rule 504’s allowance for non-accredited investors and its relative simplicity becomes a possible solution. We note here that a Rule 504 offering does not preempt state securities registration requirements as other exemptions do, so state law compliance must be taken into account.

Avoiding bad actor disqualification

Like the other Reg D exemptions, Rule 504 contains a “bad actor” provision, which disallows certain people and issuers from being able to avail themselves of the exemption. So, what is a bad actor and do cannabis companies by virtue of trading in a federally illegal substance qualify as one? The short answer is no.

For the purposes of this post, the bad actor provision in Rule 504 disqualifies any issuer from taking advantage of the exception from having to register securities if its directors, general partners, managers, executive officers, or persons with more than 20% voting power of the offeror have certain criminal convictions.

Relevant criminal convictions

Fortunately, all of the convictions and other disqualifying events as stated by the SEC are focused almost exclusively on securities related offenses. While operating a cannabis business is technical unlawful under the Controlled Substances Act, none of the disqualifying events are characterized by violations of federal law not involving securities. So, while the term “bad actor” may seem like it could prohibit a marijuana company from offering unregistered securities under Rule 504, that is not the case.

Indeed, many cannabis companies raise capital by offering exempted securities under Rule 504 and applicable state exemptions. Its allowance for non-accredited investor participation also makes it uniquely suited to the situation many cannabis businesses find themselves in and their capital needs.

For more information, see:

The post Are 504 Private Placement Security Offerings Allowed in Cannabis Businesses? appeared first on Harris Sliwoski LLP.

]]>
公开交易的大麻公司计划进行5亿美元(!)的EB-5融资(!!)。 https://harris-sliwoski.com/cannalawblog/publicly-traded-cannabis-company-plans-500m-eb-5-raise/ Tue, 07 Mar 2023 15:00:45 +0000 https://harris-sliwoski.com/?post_type=cannalawblog&p=130156 Cannabis and business immigration don’t mix. Or at least that’s the conservative guidance we often give clients that come to us with that question. That’s not because a particular investment may not be sound, rather because federal law creates inherent conflicts between immigration eligibility and participating in a cannabis venture. Kate Robertson at MJBizDaily reported

The post Publicly Traded Cannabis Company Plans $500M (!) EB-5 Raise (!!) appeared first on Harris Sliwoski LLP.

]]>
Cannabis and business immigration don’t mix. Or at least that’s the conservative guidance we often give clients that come to us with that question. That’s not because a particular investment may not be sound, rather because federal law creates inherent conflicts between immigration eligibility and participating in a cannabis venture.

Kate Robertson at MJBizDaily reported on March 1, on a first of its kind development in the space. Bright Green Corp., a publicly traded company on the Nasdaq exchange is planning to raise half a billion dollars in foreign capital through the U.S. EB-5 program. At first blush, that seems patently insane. But, there are a few important aspects of Bright Green’s proposal and 2022 EB-5 regulations that, at least in principal, make it more of a wildly risky gambit.

Cannabis and immigration

U.S. Immigration law is contained in the Immigration and Nationality Act (“INA”). The INA is federal law and administered by the U.S. Citizenship and Immigration Services (“USCIS”). Similarly, in spite of dozens of states enacting legislation that allows for recreational or medicinal use of cannabis, it remains federally illegal to possess, produce, and sell under the Controlled Substances Act (“CSA”) as a schedule I substance. The INA contains many penalties and bars to U.S. admissibility for violating federal law, including the CSA. Among them are bars to admissibility to the U.S. in the first instance and bars to being able to naturalize as a citizen down the road. For analysis of cannabis and naturalization, see Canna Law Blog posts here and here.

The INA provides that a person who is or has been a knowing aider, abettor, etc. in the illicit trafficking of any controlled substance under the CSA is inadmissible to the U.S. This begs the question: is it the case that an investment in a cannabis business makes a person an “aider, abettor, conspirator” of trafficking in an illicit substance? Not necessarily. Most lawyers would likely say that an active investment, meaning also having a role in running the cannabis business would violate the INA. On the other hand, some may say that a passive investment (not having an active role in running the business) would not. In either case, we rarely get to this analysis because lawful residence in the U.S. is the goal for most immigrant investors. Rolling the dice on an investment with questionable approvability is often an untenable risk.

This might make one wonder, why would Bright Green try to raise capital through investment immigration in the U.S., if there is substantial risk the investment may not be approved in the first place?

EB-5 and cannabis immigration

The answer requires a brief discussion of EB-5. The INA contains an immigrant investor program at 8 USC § 1153(b)(5) that allows foreign nationals to apply for permanent residence by making a minimum investment in a new commercial enterprise in the U.S. that creates or preserves 10 full time jobs as a result. The program, known as “EB-5”, is much more complex but for our purposes here that will do. The EB-5 program has since its creation yielded tens of billions in foreign investment to the U.S. and likewise created or preserved hundreds of thousands of jobs for U.S. workers.

In March of 2022, the EB-5 Reform and Integrity Act (“RIA”) was passed. The RIA contains much needed investor protection provisions and creates a stricter compliance and reporting regime for EB-5 project offerors and regional centers. Regional centers are USCIS approved economic entities that are now required to sponsor any EB-5 project with multiple investors (like Bright Green’s proposed project).

Regional centers now must submit applications called I-956F forms (formerly a voluntary “exemplar” filing) to USCIS before individual investors may file visa petitions. This filing must contain among other things extensive information and certifications about the offeror of the securities, the investment project manager, and all of the offering and investment documentation provided to investors. The filing contains every piece of information USCIS will scrutinize to determine project eligibility for purposes of EB-5 law. If USCIS approves an I-956F filing, that approval “shall be binding for purposes of the adjudication of subsequent petitions [filed by] immigrants investing in the same offering.”

For many investment offerors with non-traditional projects, getting investors to subscribe to the offering will likely require such pre-approval before offering it to prospective investors. As Kate Robertson pointed out in her article, this appears to be what Bright Green has done. Given that an EB-5 investment in a cannabis business is potentially disqualifying under the INA, the I-956F filing affords the Bright Green the opportunity to have USCIS  review the filing and make a binding determination about its eligibility for purposes of EB-5 law before the offering. There is no chance any cannabis company, publicly traded or otherwise, could raise $500 million of foreign investor capital in the absence of pre-approval by USICS. But the question remains, is it approvable?

The Bright Green project

Bright Green states in its press release about the project that it has built a one million square foot greenhouse for an “agricultural complex to be the largest in the world for fully-integrated and federally compliant research and drug manufacturing”. EB-5 investor funds will be used for “for working capital requirements to operate its current greenhouse facilities in Grants, New Mexico”.

While “not yet fully complaint”, Bright Green already has a memorandum of agreement “approving” its operations to supply bulk cannabis to cannabis researchers from the U.S. Drug Enforcement Administration (“DEA”), the agency tasked with enforcing the CSA. In principal at least, if the EB-5 cannabis investment is solely supplying cannabis to approved, licensed researchers pursuant to preexisting DEA approval then that is not “trafficking in an illicit substance” under the INA. This is because it is not a violation of the CSA to produce and sell cannabis to federally approved researchers. The CSA does provide for this kind of production to researchers who have gone through its highly rigorous process of approval.

It should be noted, however, that the company would need more than just a DEA letter approving this proposal in order to actually implement its plan. Further, it’s not at all clear that federally approved researchers need the amount of cannabis that the company’s 1 million square foot facility could generate. For an excellent discussion of Bright Green’s “plan” and its attendant issues, see this Substack post from Shane Pennington and Matt Zorn. Now, it’s certainly possible that only some of the enormous facility will be used for DEA approved cannabis production and other parts of the facility for non-cannabis production of other agricultural products.

With that being said, political winds shape agency action and it’s possible that a conservative administration is victorious following the 2024 presidential election. If federal agency policy like the Stephen Miller crafted, Trump Era USCIS were to reemerge, the consequences for the investors in Bright Green’s project could be nightmarish. Consider if the head of the DEA were to revoke Bright Green’s approval to produce federally legal research cannabis. That would throw the project and therefore the investors’ immigration eligibility into question under any interpretation of the INA. That is to say nothing of the attitude towards legal immigration at USCIS, which has yet to recover from the damage done by the previous administration. It is certainly possible that whatever favorable treatment this project is receiving now from the U.S. government changes course in 2025. Adjudication of EB-5  visa petitions at USCIS is currently taking between 5-7 years, so whatever happens following 2024, it will impact investors in this project.

What’s next?

Bright Green’s raise is ambitious to say the least and its federal cannabis allowance seems dubious. But, if approved by USCIS it would be the first raise of its kind pairing immigration and cannabis. Still, the project’s approvability relies on the DEA’s allowance of the company’s operations under the CSA. If the project is approved by USCIS, that will not mean that immigrant investments in cannabis business writ large are likewise approvable. Our conservative advice on this issue will remain the same until federal cannabis reform takes place, irrespective of Bright Green’s project approval.

We will monitor developments on this prospective raise and all things cannabis and immigration here at the Canna Law Blog.

The post Publicly Traded Cannabis Company Plans $500M (!) EB-5 Raise (!!) appeared first on Harris Sliwoski LLP.

]]>
华盛顿州LCB为社会公平大麻许可证持有者更新DIA地图 https://harris-sliwoski.com/cannalawblog/washington-lcb-updates-dia-map-for-social-equity-cannabis-licensees/ Mon, 06 Feb 2023 15:00:35 +0000 https://harris-sliwoski.com/?post_type=cannalawblog&p=129825 On February 2, 2023, the Washington State Liquor and Cannabis Board (“LCB”) released an update regarding the interactive mapping tool for determining whether people meet have lived in Disproportionately Impacted Areas (“DIA”). As we wrote about here, having lived in a DIA for at least five years between 1980 and 2010 is one of three

The post Washington LCB Updates DIA Map for Social Equity Cannabis Licensees appeared first on Harris Sliwoski LLP.

]]>
On February 2, 2023, the Washington State Liquor and Cannabis Board (“LCB”) released an update regarding the interactive mapping tool for determining whether people meet have lived in Disproportionately Impacted Areas (“DIA”). As we wrote about here, having lived in a DIA for at least five years between 1980 and 2010 is one of three possible eligibility criteria for the forthcoming Social Equity in Cannabis (“SEIC”) program, which opens for applications March 1. We wrote about that here. The map can be found by a link on the LCB’s website, or here.

Increased threshold rate in the new DIA map

Prior to the update, to qualify as a DIA, an individual census tract must have been in the top 20% on all of the following indicators:

  • high poverty rate;
  • high rate of participation in income-based federal programs;
  • High rate of unemployment; and
  • High rate of convictions.

The update states the LCB has increased the qualifying threshold to now include census tracts in the top 30% of the above factors. We note our concerns from a recent post about the mapping tool that while it may be safe to assume that it relies on 10-year national census data, it is far from clear what exactly an eligibility showing on the mapping tool really means.

Ultimately, the mapping tool is only intended for applicants to collect information about their eligibility. As the LCB notes on the mapping tool “The final determination about whether an applicant lived in a disproportionately impacted area will be made by the third-party reviewer”.

cannabis laws by state

View the US Map of Marijuana Legality

Impact of the new DIA map

The LCB’s update states that community members were concerned that “the maps did not identify enough places that were more likely to have been impacted by the war on drugs”. This is a quick acquiescence by the LCB to concerns of community members and stakeholders, which should be applauded. It’s likely that the 20% threshold was too low and as barring many prospective applicants from establishing eligibility for an SEIC application.

It should come as no surprise that limiting DIA eligibility to census tracts in the top 20% of poverty, unemployment, and criminal conviction rates resulted in too few prospective applicants having interest in the program, and others being barred from eligibility on this basis. Many people having lived or living in such census tracts, by definition, may have a tough time starting a retail cannabis operation for a host of reasons. The absence of disposable time and income necessary to either quit a job and invest in or spend time raising capital to start a cannabis business venture being the most obvious.

Starting and operating cannabis businesses is not a cheap proposition. These businesses are subject to extraordinary tax burdens, a shortage of traditional banking and lending opportunities, and an absurdly restrictive regulatory landscape. These factors are only a few of the many challenges Washington cannabis businesses face that make for slim margins, particularly in a bottomed out regional market for the commodity.

By increasing the threshold DIA rate to 30%, it stands to reason that more prospective applicants will become eligible that have the time and capital to apply for these licenses. Thanks to continuing community member and stakeholder involvement in the development of the program it seems unlikely that the increase will have any negative impact on its purpose. This is the right move by the LCB and will hopefully increase the number of eligible applicants.

The application window opens for 30 days on March 1 and hopefully this development increases opportunities for more people disaffected by the war on drugs. Let’s see how it goes.

Need Help With Washington Cannabis Law?

Contact Us

The post Washington LCB Updates DIA Map for Social Equity Cannabis Licensees appeared first on Harris Sliwoski LLP.

]]>
华盛顿州社会公平的大麻许可窗口于3月1日开放 https://harris-sliwoski.com/cannalawblog/washington-social-equity-in-cannabis-licensing-window-opens-march-1/ Fri, 20 Jan 2023 15:00:10 +0000 https://harris-sliwoski.com/?post_type=cannalawblog&p=129403 The Washington State Liquor and Cannabis Board (“WSLCB”) announced this Wednesday, January 18, that the 30 day window to apply for a Washington Social Equity In Cannabis Retail License will open March 1, 2023. The WSLCB will reissue 44 retail licenses to qualified applicants that rank the highest on a points scale to “prioritize” applicants.

The post Washington Social Equity In Cannabis Licensing Window Opens March 1 appeared first on Harris Sliwoski LLP.

]]>
The Washington State Liquor and Cannabis Board (“WSLCB”) announced this Wednesday, January 18, that the 30 day window to apply for a Washington Social Equity In Cannabis Retail License will open March 1, 2023.

The WSLCB will reissue 44 retail licenses to qualified applicants that rank the highest on a points scale to “prioritize” applicants. The licenses will be anchored to specific counties. As a refresher, we’ve been following the developments in Washington’s efforts to add Section 570 to Washington Annotated Code (“WAC”) Title 314-55 from the draft rules and their issues, the final (and unchanged) rule, and the recently released, rather unhelpful Disproportionately Impacted Area (“DIA”) mapping tool.

The license application process will be completed electronically on the WA Department of Revenue’s business licensing system, though it is not currently available on the DOR’s website.

Washington social equity cannabis license eligibility criteria

To qualify for a license and before being ranked according to the point system, an applicant must be a Washington resident, must own at least 51% of each social equity retail business, and the person or persons owning the business must meet at least two of the following qualifications:

  • the applicant has lived in a DIA in WA for a minimum of 5 years between 1980 and 2010;
  • the applicant or a family member of the applicant has been arrested or convicted of a cannabis offense; or
  • the applicant’s household income in the year prior to submitting the application was less than the median household income within the state of Washington.

While it is not listed specifically as a qualification, applicants must also submit a “social equity plan” describing how they will meet social equity goals, “applicant’s personal or family history with the criminal justice system, including any offenses involving cannabis” and a “business plan involving partnerships or assistance to organizations or residents with connections or contributions to populations with a history of high rates of enforcement of cannabis prohibition.” WAC 314-55-570(h)((i).

RCW 69.50.335 defines Social equity goals as “(i) increasing the number of marijuana retailer licenses held by social equity applicants from disproportionately impacted areas; and (ii) reducing accumulated harm suffered by individuals, families, and local areas subject to severe impacts from the historical application and enforcement of marijuana prohibition laws.” Having a social equity plan will impact eligibility and ranking so it is important for applicants to put the time in to create one.

Washington social equity cannabis license scoring rubric

Once found eligible according to the criteria above, applicants are ranked in order of priority based on a scoring system.

Eligibility requirements Point Scale
1. Lived in a disproportionately impacted area (DIA) 40
1a. How long have you lived in a DIA?

5y-10y = 10 points

10+ years = 20 points

40
2. Convicted of a drug offense? (Self) 10
2a. Convicted of a cannabis offense? (Self) 40
3. Convicted of a drug offense? (Family) 5
3a. Convicted of a cannabis offense? (Family) 5
4. If you were convicted of a cannabis offense, what type of sentence did you receive:

Fine = 10 points

Served probation = 20 points

Confined to home = 40 points

Served time in jail or prison = 80 points

80
5. Did you or your family member’s incarceration keep you from getting employment? 5
6. Did you lose your home or ability to purchase a home or rent a home as a result of your convictions or arrests?  5
7. Is your household income less than the median household income within the state of Washington as calculated by the United States Census Bureau? 40
8. Did you own or operate a medical cannabis dispensary or collective garden, licensed as a business, prior to July 1, 2016 (10 points)?

Or

Did you own and operate a medical cannabis dispensary or collective garden licensed as a business in a DIA (30 points)?

10

 

 

30 in DIA

9. Have you held or do you currently hold 51 percent majority/controlling interest of a state cannabis (marijuana) retailer license?

No = 10 points

Yes = 0 points

10
TOTAL POINTS (out of 310)

Washington social equity license restrictions

If a license is be granted, there are license restrictions Washington social equity cannabis applicants should know about. The more heavy-handed (and unnecessary) restrictions are:

  • No ownership changes to the application are allowed after it has been reviewed;
  • No change of location outside of the county in which the license is initially issued;
  • No license transfer or assumption is allowed within the first year of issuance and all social equity licenses may only be transferred or assumed by a person or persons who meet the definition of a social equity program applicant for 5 years from the date the license is approved.

These restrictions dramatically reduce the transferability of a social equity license, which are hard to transfer as it is. As we wrote on this issue last year “Many licensees will build their businesses into prosperous enterprises and this rule knee-caps their ability to sell them in the already highly (and unnecessarily) restricted WA market.” The eligibility and ranking criteria have their own issues, but the license restrictions are only going to hurt licensees–the very people the rule is intended to serve.

Still interested?

Applicants who are interested in applying for these licenses can find certain informational materials on the WSLCB website and attend a few upcoming webinars. This process may be made more complex by the possibly of lawsuits being filed to challenge certain aspects of the rule. If that happens, it could freeze or complicate the application process so staying up to date with developments from the WSLCB will be important. As usual, we will also be writing about them here.

Need Help With Washington Cannabis Law?

Contact Us

The post Washington Social Equity In Cannabis Licensing Window Opens March 1 appeared first on Harris Sliwoski LLP.

]]>