The Medicinal Cannabis (R)evolution

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are consistent product quality, avoidance of contamination and record keeping. The GAP framework integrates responsible agricultural operation and production including packing. Specific pieces of legislation and national regulatory agencies in different countries follow the guidelines of GMP and GAP. Policy makers in the ECCU should be familiar with these guidelines. • The inconsistency between the state and federal levels has led to a number of challenges for the regional banking sector as the financial industry seeks to preserve correspondent banking relations, particularly as it relates to the USA. It has been noted that 32.0 per cent of correspondent banking relationships are concentrated with US banks. Given this concentration, it is therefore recommended that both the regulator and financial institutions continue to engage with correspondent banks, not only to preserve existing relationships but also to establish new relationships. • There is need for the implementation of a strong supervisory framework to guide the conduct of the medicinal cannabis industry. This would be critical to the process, in ensuring that the benefits of the medicinal cannabis industry are fully recognised. It is recommended that the ECCB develop and implement supervisory guidelines to assist licensed financial institutions in managing the relationships with participants of the medicinal cannabis industry. Part of this framework should include the requirement to ensure that funds obtained from medicinal cannabis is adequately controlled, through an effective ring-fencing system and the establishment of a Chinese wall to ensure that funds are not comingled and transferred through correspondent banks in jurisdictions where medicinal cannabis remains illegal. A robust legislative framework for the regulation and supervision of the medicinal cannabis industry should be achieved. Specifically, the licensing authority for medicinal cannabis needs to effectively implement its responsibility of developing, implementing, maintaining and enforcing systems to supervise and regulate the cultivation, transportation, distribution and use of medicinal cannabis.