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![handle is hein.journals/wshuvylw101 and id is 1 raw text is: Washington University
Law Review Online
VOLUME 101 2023
WHY U.S. STATES NEED THEIR OWN CANNABIS
INDUSTRY BANKS
CHRISTOPH HENKEL* & RANDALL K. JOHNSON**
ABSTRACT
The legal cannabis trade is the fastest growing industry in the United
States. In 2019, about 48.2 million Americans used the drug at least once.'
As such, it is easy to see why the legal cannabis trade may generate annual
revenues exceeding $30 billion in Fiscal Year 2022 alone.2
One inconvenient truth, however, is that the parties to any cannabis
trade may face a range of difficulties due to conflicts between federal and
state laws.3 These difficulties include the fact that many financial
institutions are reluctant to handle cannabis proceeds. One reason is that a
* Professor of Law, Drake University Law School.
** Professor of Law, University of Missouri-Kansas City, School of Law.
1. See Marijuana and Public Health, Data and Statistics, CTRS. FOR DISEASE CONTROL &
PREVENTION (June 8, 2021), https://www.cdc.gov/marijuana/data-statistics.htm [https://perma.cc/E34J-
GXKZ].
2. See Report: U.S. Cannabis Sales CouldExceed $30Billion by 2022, BuRNs & WILCOX (Aug.
4, 2021), https://www.burnsandwilcox.com/insights/report-u-s-cannabis-sales-could-exceed-30-billion-
by-2022/#:~:text=Legal%/o20cannabis%/o20sales%/o20in%/o20the%/020U.S.%o20could%/o20exceed,reaching
%20%2428%20billion%20in%20yearlyo20sales%20by%202022 [https://perma.cc/J5SP-XC3X]
(explaining that [1]egal cannabis sales in the U.S. could exceed $30 billion by 2022).
3. See Legal Info. Inst., Conflict of Laws, CORNELL L. SCH. (Aug. 2022),
https://www.law.cornell.edu/wex/conflictoflaws#:~:text=Conflict%200fPo2Olaws%20refers%20to,r
esolve%20each%20issue%20in%20dispute [https://perma.cc/VPD3-BHHJ] (defining the term to mean
that [c]onflict of laws refers to a difference between the laws of two or more jurisdictions with some
connection to a case, such that the outcome depends on which jurisdiction's law will be used to resolve
each issue in dispute. The conflicting legal rules may come from U.S. federal law, the laws of U.S. states,
or the laws of other countries.).
1](ViewImageLocal?handle=hein.journals/wshuvylw101&div=1&collection=&method=preview&ext=.png&size=3)