Sterling Compliance LLC

Verified Vendor


STERLING COMPLIANCE was forged out of a strong bond of integrity, shared vision and unwavering commitment to excellence in compliance consulting. At Sterling Compliance, we bring a balanced perspective to our clients for practical approaches to regulatory compliance with battle-tested, effective results. Our nearly 40 years of combined experience managing and regulating financial institutions allows us to build meaningful, long-term value-added relationships with our clients. Our mission is to be an integral, independent resource to your compliance management team so that you can focus on the business of growing your institution and building franchise value.


Marijuana Banking Solutions

“Marijuana?” We won’t touch it.” This statement is unrealistic. Whether you have a risk appetite to directly bank marijuana-related businesses or you prefer to avoid it, it’s here and you have decisions to make. The grocery store you’ve banked for 40 years now sells CBD oil; your physician is on the approved list for your state; your mortgage applicant works for a dispensary; and, your employees may now have legal prescriptions for medical marijuana.How are you identifying these activities and the associated risk?If your position is to exit any marijuana-related business customers, what does that mean for your portfolio or your liquidity position?Some institutions taking this posture are seeing a significant exodus of low-cost deposits, so it’s not solely a regulatory compliance issue.

Given the dichotomy between Federal and State rules, we are in a strange and often frustrating regulatory environment.While the passage of the Farm Bill in 2018 legalized hemp under shared State-Federal guidelines, it has added a layer of complexity to Marijuana-Banking Programs and the associated due diligence that must be performed to determine whether a “hemp” customer is operating legally.

Sterling has been following this industry closely. We are continually developing tools and providing educational materials to assist you in identifying, measuring, monitoring and managing the risk associated with banking (or not banking) marijuana-related businesses. Whether you need consultative advice or more hands-on assistance establishing your infrastructure, we offer a suite of customizable and comprehensive solutions.

  • MRB Consultation:Utilize our Beacon service to gain unlimited access to our staff for timely, thoughtful and practical answers to your questions.Our team of experts can address a broad array of topics relating to regulatory compliance, BSA|AML programs and banking marijuana or hemp-related businesses.We cut through the legalese and regulatory citations to get you what you need to make informed decisions for sound risk management.
  • MRB Risk Assessment:We have published a Marijuana-Related Banking Risk Assessment template for financial institutions to use.We understand the constraints of time and resources our clients grapple with, and we strive to continually develop tools to help you streamline your risk management processes.We work closely with our clients to develop a customized MRB Risk Assessment that, at its core, helps you determine whether you can – or should – bank MRBs.The Risk Assessment will provide a snapshot of the associated risks and drive an Action Plan that is designed to help you navigate the implementation of necessary additional controls to effectively manage your risk.
  • MRB Policy:Also published for your use, our MRB Policy template is designed to provide a sound policy structure to reflect your specific risk appetite.Our staff can assist you in developing the policy from the ground-up based on your MRB Risk Assessment or review the adequacy of the policy you’ve established.

Regardless of the speed in which our government and Federal banking agencies move, this is an industry that is continually expanding and one that is inevitable. It is critical that you know how to effectively address and manage your risk, whether you are going to bank MRBs or steer clear. Let us be your guide.

Compliance Consulting and Review Services


Our comprehensive Compliance Services are designed to strengthen and maximize the efficiency of your Compliance Program. You may select from a menu of services including, but not limited to, compliance review services, consulting, risk management and customized policies and procedures. Select one service or combine a variety of services. Each engagement is specifically tailored to your individual needs and preferences.

Risk Management


Assessing the level and direction of risk within your institution is critical to your ongoing operational, strategic and regulatory compliance responsibilities. Your risk assessment process must be robust enough to identify current, as well as emerging risks, to ensure the implementation of effective and appropriate controls to mitigate identified risks. We can help you through the full life cycle of risk management, from the initial risk assessment process to the development of a formally documented risk management program, including policies and procedures, to testing the effectiveness of mitigating controls and implementing appropriate enhancements or corrective measures. We will help you through each step of this process to ensure all relevant areas of the bank are appropriately integrated into your business strategy, decision-making framework and daily operations.

Customized Policies


Creating written compliance policies and procedures can be daunting, and buying them “off the shelf” is often just as cumbersome because you still have to wade through the boilerplate language and customize the document to fit your unique business model. We take the pain out of that process by customizing policies and procedures for you based on dialogue with Management and business line managers to understand your products and services, internal controls and workflows specific to your shop. Our policies and procedures are compliant with applicable regulations and designed to streamline workflows and provide practical, effective controls that are not an impediment to business. We then provide turnkey documents that you can take to your Board for approval and implement with ease. We can also assist with the implementation process by providing in-bank training to explain the regulatory and policy guidelines and material changes to any processes or workflows.



At Sterling Compliance, we believe in early, ongoing and effective educational opportunities. In addition to our educational events, we offer you several options to obtain cost-effective, interactive training that is tailored to your specific institution.



With one regulatory wave after another, it starts to feel like we’re drifting farther and farther away from solid ground. That’s where we come in. Our Navigator newsletter will help you steady your rudder and guide you safely through the turbulent waters of regulation and compliance exams. We’ve designed the Navigator to be your go-to resource for compliance news, critical and upcoming deadlines and items of regulatory focus.

The Navigator regularly features:

Relevant articles addressing current compliance issues. These articles are designed to inform you and provide perspective of the impact of regulatory guidance and upcoming legislation for your institution. We include practical implementation tips and useful resources to guide you through the processes of understanding compliance issues, implementing proper controls to mitigate risk associated with those issues and approaching your compliance examinations with confidence.

Critical dates. We will keep you informed of critical dates relating to the implementation of regulatory guidance and the status of proposed legislation.

Upcoming Events. Learn where we will be and how you can join us! Whether we are holding Compliance Roundtables, Continuing Education Courses, Forum Events, or Webinars, our Upcoming Events section of the Navigator will provide you information about each event and how to register.

Sterling BEACON


We offer a monthly consulting service that gives you unlimited access to our compliance experts for any compliance-related questions. This service is part of all compliance engagement packages, but may be selected a la carte for your institution. Our Beacon allows you to call or email us any time – an important compliance lifeline!