Bancos e maconha nos EUA: porquê separados?

WAW

hempadao 14 outubro, 2016

Em quase metade dos estados dos EUA, o negócio da maconha vem bem. Apesar da maconha ser ilegal sob lei federal, 23 estados (na época) legalizaram algum uso de maconha. Colorado e Washington permitem até mesmo uso recreativo…

Autora: Julie Andersen Hill, Professora Associada de Direito, Universidade do Alabama

Publicado originalmente no The Conversation, em 27 de outubro de 2014. Leia o artigo original%22The Conversation%22 logoThe Conversation
Tradução por Anders Bateva

Mas, novos negócios da maconha têm um problema em comum para encarar: eles não podem ter contas bancárias. Ao invés disto, os negócios da maconha operam baseados apenas em dinheiro-vivo. Quando eles precisam pagar impostos ou fornecedores, eles disfarçam o dinheiro ou contratam guardas armados.

Manter os negócios da maconha fora do sistema bancário causa problemas tanto para os negócios quanto para os reguladores. Os negócios precisam se proteger de ladrões.

Em uma ocasião, um vendedor de maconha medicinal na Califórnia alegadamente foi sequestrado e torturado por ladrões em busca de dinheiro vivo. Ao mesmo tempo, reguladores e agentes da lei precisam ter certeza de que o dinheiro fluindo para dentro de negócios de maconha está adequadamente taxado, e não é desviado para empresas criminosas.

Negócios que operam apenas em dinheiro vivo são notórios paraísos para truques contra impostos. Então, porquê não podem os bancos aceitar negociações da indústria de maconha estadualmente legalizada? Há três razões relacionadas.

– Leis criminais

Independente da lei estadual, a lei criminal federal diz que a maconha é ilegal. O Ato de Substâncias Controladas proíbe manufatura, distribuição, ou dispensa de maconha.

Bancos que ajudarem a indústria da maconha podem ser considerados culpados de “auxiliar e encorajar” produção de maconha ou “conspirar” para dispensar maconha. Também é crime lavar dinheiro – engajar-se em transações sabendo que o dinheiro veio da maconha.

O Departamento de Justiça reconhece que ele não possui os recursos para investigar e processar todo crime relacionado à maconha. Ao invés disto, este Departamento lançou um guia onde anunciava uma certa quantia de prioridades de cumprimento da lei, como prevenir a distribuição de maconha para menores de idade, e prevenir o desvio da maconha de estados onde ela é legal sob lei estadual, para outros onde não é.

Cultivadores de maconha e varejistas baseiam-se no guia de prioridades de cumprimento da lei publiado pelo Departamento de Justiça. Essas pessoas abrem instalações e dispensários confiando que as autoridades federais não irão prendê-los ou confiscar a propriedade deles. Mas os bancos não estão tão confiantes.

Os bancos têm muito mais a perder caso o governo federal mude suas prioridades. Diferente dos “empresários da ganja”, bancos existentes têm negócios estabelecidos e significante rendimento que não estão atrelados à indústria da maconha.

Também os bancos têm muito menos habilidade de protegerem-se de processos. Um dispensário de maconha pode adotar práticas que reduzem o risco de vender maconha sem-querer para um menor de idade. Em contraste, um banco precisaria depender largamente da palavra do dispensário, de que os menores não estão sendo permitidos a comprar maconha. Portanto, os bancos não oferecem serviços bancários para a maconha pois temem poder ser criminalmente processados.

Lavagem de dinheiro

Leis anti-lavagem de dinheiro impõem uma alta pressão de conformidade sobre os bancos. Os bancos precisam reportar transações suspeitas envolvendo mais de US$5mil para o FinCEN, Rede (federal) de Combate a Crimes Financeiros. O FinCEN diz que basicamente toda transação envolvendo dinheiro de maconha é suspeita.

Se as transações de maconha envolvem uma prioridade de cumprimento da lei, como (evitar) a venda de maconha para menores de idade, o FinCEN espera que os bancos incluam tais informações no reporte. Preencher esses reportes de atividades suspeitas consome tempo e é custoso.

Error podem levar a penas criminais e multas. Alguns bancos não estão dispostos a se submeter a este peso de conformidade, e o riscos que vêm com ele.

Regulação bancária

Os bancos devem responder a vários reguladores federais – reguladores que não parecem estar empolgados sobre serviç

os bancários para maconha. Por exemplo, a FDIC, Corporação Federal de Seguros de Depósitos, provê seguros federais de depósitos para contas bancárias.

Bancos nos Estados Unidos não podem operar sem seguros de depósitos. O FDIC alerta que os bancos “necessitam assegurar eles mesmos que não estão facilitando atividades ilegais [de seus clientes]”. Se um banco ignorar os avisos, a corporação pode revogar os seguros de depósitos, e forçar o fechamento do banco.

Quando reguladores federais são perguntados diretamente sobre serviços bancários de maconha, eles evadem. Mais cedo neste ano (2014), o governador do Colorado, John W. Hickenlooper, e o governador de Washington, Jay Inslee, perguntaram ao FDIC, ao Conselho Administrativo da Federal Reserve, à Administração da União Nacional de Crédito, e ao Escritório do Controlador de Moedas, por orientação sobre serviços bancários para maconha.

Como resposta, os reguladores enviaram uma carta dizendo que os bancos devem reportar transações suspeitas para o FinCEN. A carta não proveu nenhuma orientação adicional. Ao invés disto, os reguladores explicaram que “mais clareza do Congresso” na questão dos serviços bancários a maconha “iria prover mais certeza legal para os bancos”.

Os reguladores federais do sistema bancário parecem estar dando a dica de que o Congresso é que tem as chaves para o acesso aos serviços bancários da maconha. Outros chegam à mesma conclusão.

A menos que o Congresso haja para descriminalizar a maconha a nível federal, as leis criminais federais evitam que o Departamento de Justiça, o FinCEN e os reguladores bancários federais possam apoiar totalmente os serviços bancários para a maconha.

Ao mesmo tempo, ação do Congresso pode não ser suficiente. Recentemente (2014), o Departamento de Justiça e o FDIC têm sido criticados por políticas que sufocam acesso bancário para clientes legais, mas de “alto risco”, como “crédito consignado”, varejistas de armas e munição, e a indústria de entretenimento adulto.

Esta experiência mostra que mesmo se a maconha for descriminalizada federalmente, os reguladores ainda detém poder significativo para manter o dinheiro da maconha fora dos bancos. A menos que o Congresso e os reguladores ajam, os negócios estadualmente-legais de maconha vão penar para encontrarparceiros financeiros.



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  297. I’ve observed that in the world nowadays, video games will be the latest phenomenon with children of all ages. There are times when it may be not possible to drag your son or daughter away from the video games. If you want the very best of both worlds, there are various educational games for kids. Good post.

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  317. Good article. I will be going through some of these issues as well..

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