The Opportunities and Burdens in California’s New Cannabis Regulations

Khurshid Khoja

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Matthew: Hi, I’m Matthew Kind. Every Monday and Wednesday look for a fresh episode where I’ll take you behind the scenes and interview the leaders of the rapidly evolving cannabis industry. Learn more at www(dot)cannainsider(dot)com. That’s www(dot)cannainsider(dot)com. Do you know that feeling when you sense opportunity, when you see something before most people and you just know it will be successful, then you're ready. Ready for CannaInsider Consulting. Learn more at www(dot)canninsider(dot)com/consulting. Now here's your program.

By itself California is the eighth largest economy in the world. However there are other reasons besides its size that people in the cannabis eco system need to watch what is happening in California very closely. California has a huge influencing impact on other states and countries around the world. So in a sense California can be seen as the future of cannabis in a microcosm. Other reasons to look at California closely is that the state has a strong tradition of investing in and adopting technology rapidly as well as a strong tradition of agriculture. All of these reasons mean that California will most likely be the very clear vanguard pushing the cannabis limits of what is adopted by governments and businesses around the world for years to come. To help us sort through what is happening with cannabis in California is Khurshid Khoja the principle and founder of Greenbridge Corporate Counsel. A business law firm representing clients in California, Washington, and Hawaii. Welcome to CannaInsider Khurshid.

Khurshid: Well thank you. I appreciate the opportunity to be on Matt. Happy to join many of my clients who’ve been on your show before and excited about the opportunity to speak with you.

Matthew: Well to give us a sense of geography can you tell us where you are in the world today?

Khurshid: Sure. So today I’m speaking to you from sunny Sacramento and the capital of the largest state cannabis market in the country and specifically today I’m at the California Cannabis Industry Association’s Policy Conference where I’ll be speaking later today.

Matthew: Okay great and before we dive into what’s happening in California specifically can you give us some more background on yourself and how you got into this cannabis business and into the start of Greenbridge?

Khurshid: Sure. So I’m the principle and founder of Greenbridge Corporate Counsel. A business law firm representing clients in California, Washington, and Hawaii from a cross sectors in the legal cannabis industry so we represent nonprofit advocacy organizations, medical marijuana collectives, consulting firms, publishing companies, consumer electronic manufacturers, infused product producers, software companies, trade associations, and a host of others including as I mentioned several guests that have been on your show before. At Greenbridge we focus on transactional and business law matters and answer questions that relate broadly to who can participate in lawful cannabis industry and under what circumstances.

Matthew: Khurshid can you give us a little color around your background in the industry and how you got started and then how it’s evolved to where you are now?

Khurshid: Sure. So I started my cannabis industry practice at the San Francisco office of a large multi-national law firm as a corporate lawyer with transactional practice that was focused on renewable energy. In 2011 I was actually terminated while hosting the very first ArcView Pitch Conference at my office. The cited reason was insubordination to firm management for my persistent efforts to try to build a cannabis industry practice inside the firm, but it was clear to me that hosting ArcView was the last straw and that I’d really pushed the envelope past the breaking point.

But I was willing to push the envelope here to get my former employer to embrace a cannabis industry practice. To me it was a very risky act of civil disobedience against the federal drug war for me to leverage my expertise as a business lawyer to help seed and protect legal cannabis businesses and one that I would’ve preferred to do so behind the professional cover of a big law firm and without a massive pay cut, but that wasn’t to be and there weren’t any other takers from among the larger law firms. So I set up shop as Greenbridge Corporate Counsel with what was left of my severance payment from that firm.

Matthew: Well that’s a great origin story from the ashes of a termination rises Greenbridge.

Khurshid: Absolutely and it’s given me a lot of opportunity and a lot of freedom as well to serve in the industry and in the movement. So early on I had the opportunity to serve as the first general counsel of the ArcView Group helping CEO and founder Troy Dayton establish the ArcView Investor Network. I also co-founded and served as the pro bono general counsel to the Emerald Grower’s Association. Since then I’ve been able to grow Greenbridge to eight lawyers and we represent clients in three states now. Currently I’m serving as the general counsel of the California Cannabis Industry Association in addition to being on its board and I’m also a board member and pro bono counsel to the National Cannabis Association and Students for Sensible Drug Policy.

The other interesting thing that I’ve been able to do since moving to Sacramento is I’ve also become a registered state lobbyist for both the ArcView Group and I’ve also joined as part of CCIA’s lobbying team in Sacramento. So that’s given me a lot of insight into how the sausage is made if you will and how we can affect change in the industry through legislative action.

Matthew: I’m curious now that you know how the sausage is made is it different than what your perception of how it is made at the state level legislature.

Khurshid: Absolutely. I mean it’s given me.. when I think about the differences between the MRSA and the AUMA the so-called Parker Initiative that is going to make the ballot in November. I think about the effect of the various stakeholders in the legislature right. So you’ve got labor, you’ve got the cities and counties, you’ve got law enforcement, you’ve got the cannabis industry, and a number of other stakeholders who are all involved in negotiating and passing the MRSA, and as a result there are a lot of things in the MRSA that industry is not wild about. I mentioned the mandatory distribution system.

Those types of features however are absent from the AUMA because here we didn’t have to deal with the various stakeholders who hold sway in the state capitol. You’re just dealing with the voters, and so you’ve got different priorities and as a result I think the AUMA ended up being a much stronger ballot initiative. And to me the adult use system is going to be far preferable to operate in California as opposed to the medical system which is hampered by different restrictions on ownership and vertical integration and again those are all part and parcel of that sausage making process where you’ve got so many cooks in the kitchen saying I want to add this, I want to add that and you don’t always get your way as a stakeholder in industry. And with ballot initiative you’re dealing with the voters you’ve got a completely different set of options. It’s a different universe of choices.

Matthew: To give us a really high level overview of what’s happening in California can you summarize the Medical Marijuana Regulation and Safety Act? When that took place and became law and what’s most important about it?

Khurshid: Sure. So the Medical Marijuana Regulation and Safety Act was signed into law last year making California a Cole Memo compliant regulated state medical marijuana market. So previous to the passage of, we call it the MRSA for short, previous to the passage of the MRSA we had a patchwork in California of local jurisdictions that were regulating cannabis at the county and city level but there was no comprehensive state regulation or state licensing of businesses in California. And so the passage of the MRSA was a big landmark not only for California but also for the industry movement as a whole given the size of this market and its position as a leader in the industry.

So the first state licenses will be issued in California in 2018 after the six regulating agencies have adopted rules implementing the act. There will be 17 different types of licenses for cultivators, manufacturers, retailers, testing labs, distributors, and transporters. Also I’d say a dual licensing system meaning that the state will not grant licenses to any businesses that don’t already have a local permit license or other authorization sorry to operate in that local jurisdiction.

Matthew: Now when you say Cole Memo compliant can you just give a little overview of what the Cole Memo is so listeners can understand what that means?

Khurshid: Sure. So the Cole Memo is guidance provided by the U.S. Department of Justice back in August 2013 and what the Cole Memo does is basically it’s a policy statement. It’s not a statement of law but a policy statement from the executive agency, executive branch of the government saying these are the conditions under which we are going to allow these various state experiments that are going on with legalization of medical and adult use cannabis. These are the conditions under which we are going to let that experiment move forward and not interfere by trying to enforce the Controlled Substances Act against compliant actors who are trying to follow their state and local law on that subject.

Matthew: And when you’re phone rings from clients in California and they’re trying to interpret and pivot and comply with the Medical Marijuana Regulation and Safety Act as much as possible are there any questions or concerns that come up over and over again?

Khurshid: Sure. So there are a number of issues that clients raise over and over again. The chief question is of course how do I get myself ready? How do I get my business ready for MRSA compliance? How do I get my business situated so that I can get a license under the state act when those licenses are available. And so that kind of opens up a whole myriad of other questions and they’re affected by things like the ownership rules that are set forth in the MRSA as well as local licensing as well. A lot of the most impactful legislation is being deliberated by California’s counties and cities because again MRSA has a dual licensing system. So while the act doesn’t impose strict numerical limits on most of the license classes authorized under MRSA these localities will De facto determine how many state licensees will ultimately be in the system by admitting or denying legitimate access to new and existing businesses.

So after an initial rush to ban many of the jurisdictions have taken a closer look at establishing local licensing and permitting schemes which are complimentary to the states scheme under the act. So a lot of the questions that I get are where should we be located that is optimal for our business and the answer is still in flux because a lot of jurisdictions have heretofore not had any kind of comprehensive regulatory scheme or a licensing scheme for these businesses. Some jurisdictions have licensed cultivation, others have limited licensing for retail outlets for dispensaries, but very few and certainly prior to the passage of MRSA very few had any rules on say manufacturing right. We know that the Vape pen market, the market for concentrates and extracts is huge and yet we have no guidance essentially at the local level on what’s permissible, what’s not, how to get the license, how to operate in compliance. And so these types of questions are being posed over and over again by various clients who want to be well situated to gain not only local licensure but also be eligible to gain state licenses when the time comes.

Matthew: Okay and now what about investors? Investors in California and out of state is there any changes or what’s it like there for people that are outside of California that want to invest in the California cannabis business?

Khurshid: Well fortunately under MRSA there isn’t a residency requirement. Under the ballot initiative that is hopefully going to be on our ballot in November the AUMA (Adult Use of Marijuana Act) that does have residency requirements but the MRSA does not so for the time being opportunities to invest in California are still open to folks who are not residents or who live outside the state. That said I mentioned the ownership rules and those are fairly complex because the ownership rules also tie into restrictions on vertical integration and what happens essentially is that you are allowed to be an applicant or an owner of a certain number of licenses.

There are various restrictions in the MRSA on what combination of licenses you can hold. And if you violate those provisions, then you are not going to be able to hold all the licenses that you want, and you may also potentially complicate the lives of other partners that you have in that venture because they may not be able to get the licenses that they need, the combination of licenses that they need. So the definition of owner in the MRSA will ultimately determine who will have the opportunity to participate in this new market. So access to investment opportunities, access to operating and expansion capital as well as the ability to employ human and financial capital across industry sectors and the ability to get your products to market. These are all going to be dependent on that question of who is an owner?

So the way MRSA currently defines an owner is problematic because it presumes an ownership interest in the licensee even where a party may only have an ownership interest in property being used by the licensee in its facility or its operations. And so this is serious implications for anyone wishing to apply for multiple state licenses along different points of the supply chain as the ability to operate a vertically integrated enterprise is again heavily restricted. It also complicates an investor’s life because diversification is very difficult to achieve in that context.

Matthew: Great points. Now you mentioned that there are seventeen different licensing opportunities. With so many categories and with new categories do you see opportunities for new types of businesses that didn’t exist in the California cannabis market before?

Khurshid: Sure. So for the first time anywhere in California there are distribution licenses and transport licenses in addition to all of the other points along the supply chain those are separately licensed classes of activity, classes of commercial cannabis activity. And so we are seeing folks interested in distribution licenses to help producers get their products to the retail market. Not everyone is quite thrilled to see these new licenses because again with the restrictions on vertical integration you can’t hold a distributor’s license and have a dispensary license or have a cultivator’s license or manufacturer’s license for that matter. So you’re basically dealing with a mandatory distribution system but other owners from along the; other licensees from along the supply chain are not actually allowed to have any kind of interest in that distributors license.

So while there are opportunities and certainly there are operators who would welcome having a distributor handle distribution of their products that they can focus on what they do best. Not everyone is wild about the mandatory nature of the distribution system in California.

Matthew: Just because it allows them less options is there a concern of fiefdoms being created or cartels or something?

Khurshid: Yeah there’s concern about smaller producers not being able to have their products reach the market because they don’t have the kind of leverage when they’re dealing with a very large distributor that is dealing with dozens and dozens of producers and so there is a concern about will my products actually be acceptable? Will I have to modify my products or my business itself in order to get to market because of the leverage that the distributors are going to have? There’s also concerns among the testing labs where again what happens if the testing labs reject too much of the product that the distributors are trying to distribute? Will there be some backlash there? Is it going to be harder for the labs to operate and for them to guarantee the integrity of products reaching the market if they’re dealing with a few very large distributors and those are the only outlets for their services and the only ways to get products to the retail market?

Matthew: Can you explain what BMMR is or BMMR what that acronym means and why people in the California cannabis community should be interested in it?

Khurshid: Sure. So BMMR, B-M-M-R is the Bureau of Medical Marijuana Regulation which was created by the MRSA under the Department of Consumer Affairs to oversee general administration and enforcement of MRSA through multiple; well they are the lead agency. However there are number of other agencies, state agencies that are going to be taking a prominent role and problem getting regulations to implement the act. So BMMR is the agency that is going to oversee all of this but ultimately there are going to be six plus agencies that are involved in the implementation of the MRSA. That being said the success of BMMR is going to require interagency cooperation of all these agencies all of which are new to regulating cannabis.

None of the regulating agencies have actually formally begun the rule making process. These agencies have been in the process of meeting with stakeholders so BMMR is still kind of in formation if you will. I just heard from the new head of BMMR, Lori Ajax at our conference this morning and they are quickly staffing up. They have three permanent staff right now. Again they’ve just started and they’re going to be looking for legal counsel to help them with the rule making that’s coming up and as I mentioned there are six plus agencies including Department of Food and Ag, Public Health, Consumer Affairs, Pesticide Regulation, Fish and Wildlife, and the State Water Resources Control Board.

Matthew: Wow. That’s a lot of government.

Khurshid: Yeah it’s alphabet soup.

Matthew: Yeah. Are there any deadlines that listeners should be aware of or anything coming up on the horizon that’s important that they should make note of?

Khurshid: Absolutely. So I mentioned the rule making proceedings that have not begun yet but they do have to be concluded within one year. And so the agencies have and BMMR specifically has said we want to be in a position to be able to grant licenses by January 1st, 2018 which means that they’re going to have to get the rule making proceedings done well before then. The rule making timeline is a year long. So the rule makings have to be concluded within a year and we can expect that these proceedings will probably begin no later than the end of this year, although some agencies like DFA the Department of Food and Ag anticipate being done by summer of 2017 and others are a little bit less saying when but the Bureau is committed to making sure that all of this is done by the time January 1st, 2018 rolls around. That’s the date when they can start granting state licenses.

Matthew: We see established cannabis businesses in California such as MedWest get raided and continuing raids going on. How is this possible that a legal cannabis business gets raided? In this case I think was a local jurisdiction in southern California partially funded with federal funds from Homeland Security. Can you tell us a little bit about your thoughts around that? Why raids continue and where we’re at in this process?

Khurshid: So the MedWest raid was very unfortunate. I’m good friends with James Sladdock and others at MedWest and really sad to hear about that raid. What I know of it is that while there was some federal funding likely involved in the agencies that were participating in the raid it wasn’t actually a federal raid. It was a local police action taken by the city on the grounds that MedWest was not complying with zoning requirements and so that seems to be the impotence for that raid and so we know from earlier in the year there was; we had the Robocker Farm renewed and that is a provision in the Federal Budget Act that says that federal officials are not allowed to spend any federal money on enforcing the Controlled Substances Act in states that have legalized medical or adult use cannabis and so they have been barred from participating in those raids. Federal officials have been barred by federal courts from participating in those raids and so what we’re seeing now is local action and some local level carnage that may not be over yet.

There are a number of folks, businesses who are trying their damnest to comply with state law and be good actors but a lot of these folks are still operating in a irregulatory void at the local level and there has to be more evolution of these local ordinances on licensing before that is going to come to an end. By and large though I think we’ve seen local jurisdictions that have recognized the fact that they’ve got thriving businesses in their jurisdiction and they don’t want to make them criminals. They want to bring them above ground and they do want to collect that tax revenue. That being said there are dozens and dozens of jurisdictions that have actually banned activity as well. And so if there is any commercial cannabis activity in those jurisdictions certainly there you’re going to see more enforcement actions against these businesses as time progresses but again at the local level not so much the federal.

Matthew: Civil asset forfeiture seems to be a tool in the toolbelts put authorities in these raids. Can you talk a little bit about how that was used if you know anything about it?

Khurshid: Well I know that in the MedWest raid it’s actually not a federal asset forfeiture action. There is a state corollary to that so there are state asset forfeiture laws that apply and I believe that’s what’s being used here in the MedWest case. I don’t know enough about it to really comment on the substance of the allegations that the city has brought but presumably if they have invoked the state asset forfeiture proceedings then they are alleging that there has been some unlawful action and that is largely due to the fact that in these jurisdictions local businesses cannot rely upon the affirmative defenses that are currently available to them under California Medical Marijuana laws and so where they can’t rely on these affirmative defenses in these jurisdictions that have been unfriendly they are going to be subject to prosecution under the criminal cannabis laws that apply to everybody else outside the patient community and so that is going to be the underlying premise of any state forfeiture action. Again I hope that they are able to resolve and settle this matter with the city before it gets to that point but it’s very scary for any business owner to be facing that.

Matthew: Right and what I understood from the video that James Sladdock and MedWest put out is that his financial assets not just his but his wife and his children’s were all frozen immediately. So you’re essentially barred from having any resources to creating your own defense. It’s kind of like saying hey to a boxer hey get in the ring with me but I’ve created a technicality where you can’t even get in the ring and begin to fight because I make up the rules.

Khurshid: Yeah.

Matthew: I mean it seems like such a backward Draconian system we have here. Is this pretty common that assets are frozen in such a way that you can’t even defend yourself?

Khurshid:: I’ve heard that over and over again from other operators who’ve had to face this type of a proceeding that they freeze all the assets including your family assets and yeah it’s very difficult for you to fight back. I look at the asset forfeiture laws generally as a license for law enforcement to steal. And so given that the law is set up that way I’m not surprised to hear that they would try to hobble anyone from fighting back. It takes a long, long time to fight back and to actually reclaim your property and your business. So asset forfeiture that I would like to see as an area of reform not only in California but at the federal level as well. Like I said I think it’s a license to steal and it doesn’t conform with our constitutional privileges that we have under the U.S. Constitution in my opinion.

Matthew: Agreed. Well moving outside of California what issues are top of mind for you right now at the national level?

Khurshid: Sure so banking access is one area that really needs massive improvement. We don’t have; although we do have guidance from the Department of Treasury and FinCEN the Financial Crimes Enforcement Network both executive federal agencies. They’ve provided guidance on how businesses and banks can work together. How banks can actually offer their services to state lawful cannabis businesses the number of banks actually doing so is still very small. You don’t see a lot of big national publicly traded banks for example wanting to jump into this consumer base. They are very hesitant because right now as it stands the guidance that they’ve been given really imposes a lot of additional duties on the banks that really are not appropriate for the banks to carry out; more appropriate for law enforcement and the state to carry out and so you don’t see a lot of takers among the banks and that’s going to have to change if we are going to actually have a mature industry and one that is able to grow and hopefully grow at some point federally nationwide as well. Until that happens we’re not going to be able to scale those operations and not going to be able to protect public safety in the process as well.

When we don’t have banking access there’s a lot of cash flowing and even the simple matter of going to pay your taxes can be a pretty stressful experience if you’ve got a hundred thousand dollars in your backpack and you’re walking in without any kind of guard and so that’s a problem and so states have tried to solve this issue. In California there is a lot of interest in trying to start a state bank. I’m not so sure that that is going to be a workable alternative. First of all it takes a lot of capital, a lot of time, and a lot of effort to actually set up a financial institution like that and even if you were successful in doing so the FDIC is the regulator of last resort for banks that aren’t part of a Federal Reserve System which is what a state chartered bank would be and the FDIC itself has not shown itself to be very enlightened. They’ve denied deposit insurance to other banking institutions who were attempting to comply with FinCEN and Treasury guidelines and tried to join in the Fed system.

So I’m not so sure that the FDIC is going to welcome the advent of state chartered banks who are specializing in cannabis accounts. I think what we really need is to have a federal solution and we really need to impress upon our decision makers and Congress and any executive agencies that we need to address this situation and we need to do it on public safety grounds and so what we need is to have our state and local tax authorities talk to them about what this problem is doing on their end and how important this is for it to be resolved. The writing is on the wall. The genie is not going back into the bottle so if Congress does not address this situation they are letting a public safety issue escalate and get worse.

Matthew: And it really doesn’t need to be this way. We could look at Canada and they really have totally untangled this knot. It’s illegal to do any kind of banking around cannabis in Canada from what I understand and there’s just not any of these issues.

Khurshid: Yeah.

Matthew: And I realize we’re a different country but it’s not that hard to envision when our neighbors to the north already have a totally functional system so it’s just like hey can we have that? It’s not like we’re trying to sell them on a unicorn from another plain or something.

Khurshid: Yeah, yeah. What every operator in this industry wants is just to be treated like any other business. We want to pay our taxes. We want to follow the law. We want to create jobs and we want a fair and reasonable profit as well and so those are not unreasonable things to want if you are trying to play by the rules. Canada not only has banking but they’ve got publicly traded cannabis companies on their exchanges and what we’ve got is markedly different. Most of our companies that are publicly traded are on the pink sheets and the OTC and investors don’t get the benefit of the investor protections that they do in Canada where this is all federally legal and legitimate for them to list their stocks on the national exchanges and invite investment.

Matthew: What about pesticides at a national level? What do you think can be done there?

Khurshid: So that’s another very interesting issue. We keep seeing headlines about massive recalls in Colorado and elsewhere due to the presence of certain pesticides that are not authorized for use on cannabis and this all stems from the fact that the EPA has been largely silent on this issue. They did issue some guidance several months back to Colorado about which pesticides would be permissible potentially but they’re not taking a stance and that’s because cannabis is not defined as an agricultural crop under federal law and under federal law all pesticides have to have the parameters of their use listed on the label and anything that is used differently from what’s prescribed on the label is called off label use and that is implicitly unlawful and so the problem is that there are no pesticides really that say that this is for use on cannabis right.

There may be some pesticides that say on the label that they are generally safe to use on food crops or generally safe to use on different types of agricultural crops and those may be okay to use arguably but there are a number of pesticides that cultivators use to keep their crop safe that are not listed but are presumed to be safe but there’s no guidance from the federal government on that and so they continue to be unlawful to use and so it creates quite quandary when these recalls happen because they’re not based on federal law they’re based on a sort of state law principles that are hobbled together from EPA guidance and from what limited power the states have to regulate pesticides.

Matthew: Khurshid before we close I’d like to ask a question about a book that’s been pivotal or transformative in your life. Is there any book that you look back over the arc of time in your life and you think hey this was really a transformational book for me that really gave me new insight or different lens to view my life?

Khurshid: Sure. So when I first started my cannabis industry practice I had read “The New Jim Crow” by Michelle Alexander who is a law professor and I think currently at the ACLU and “The New Jim Crow” is a book about how the drug war essentially has created a huge prison industrial complex and massive rights of incarceration especially of people of color. When I started off; cannabis isn’t my first activist foray and so when I kind of started my career if you will as an activist I started in high school with the Anti-Apartheid Movement; the International Anti-Apartheid Movement and reading “The New Jim Crow” kind of brought things full circle for me as an activist. One of the facts that she cited was that the U.S. incarcerates a higher proportion of its black population than Apartheid era South Africa did during the height of opposition to Apartheid when they were fighting armed insurgents.

They were locking away fewer black people than we were and to me that really hit home and made me decide that this is what I’m going to do. I don’t have a choice. This is what I have to do and I’ve seen the drug war through a civil rights lens ever since and it’s definitely been transformative not only for me but for several other activists and entrepreneurs who I know were personally touched by that book. So I can’t recommend Michelle Alexander’s book enough.

Matthew: That’s an excellent suggestion. One piece of news that came out this week was about how the Richard Nixon administration used a lot of the war on drugs as a way to target minorities and protestors that were essentially giving him a hard time. What’s a reason we can come up with to go after these people the public will stomach.

Khurshid: Yeah.

Matthew: So there’s a lot of consequences we don’t; unattended consequences of legislation we don’t see sometimes and the human faces behind them so thanks again for that suggestion.

Khurshid: Sure.

Matthew: In closing how can listeners learn more about Greenbridge and the services you offer?

Khurshid: So we’ve got a website. It’s www.greenbridgelaw.com. Our bios are up there as well as our firms mission statement. We are a firm with a mission. Our mission is to help end prohibition and we’re going to do that by building a regulated taxpaying above ground economy and so we encourage folks to check out our website. Check out our mission statement and certainly contact us if they need any help.

Matthew: Khurshid thanks so much for coming on CannaInsider today. I really appreciate it.

Khurshid: Sure my pleasure, thank you Matt.

Matthew: If you enjoyed the show today, please consider leaving us a review on iTunes, Stitcher or whatever app you might be using to listen to the show. Every five star review helps us to bring the best guests to you. Learn more at www(dot)cannainsider(dot)com/itunes. What are the five major trends that will impact the cannabis industry in the next five years? Find out with your free report at www(dot)cannainsider(dot)com/trends. Have a suggestion for an awesome guest on www(dot)cannainsider(dot)com, simply send us an email at feedback(at)cannainsider(dot)com. We would love to hear from you.


Cannabis attorney Khurshid Khoja discusses both the opportunities and burdens in California’s new cannabis regulations.

Khurshid Khoja is the Principal and founder of Greenbridge Corporate Counsel, a business law firm representing clientele across sectors in the legal cannabis industry: non-profit advocacy organizations, medical marijuana collectives, consulting firms, publishing companies, consumer electronics manufacturers, infused products producers, agricultural equipment manufacturers, software companies, trade associations, and others.

Khurshid brings a wealth of experience from representing and consulting with companies in the legal cannabis industry. In addition to pioneering the Cannabis & Hemp Industry practice at Greenbridge, Khurshid was a Founding Board Member of both the California Cannabis Industry Association (CCIA) and the Illinois Cannabis Industry Association (ILCIA). He continues to serve on the CCIA Board and as its pro bono General Counsel, and was recently elected to the National Cannabis Industry Association (NCIA) Board.

Key Takeaways:
[2:27] – Why Khurshid starting Greenbridge
[6:17] – Khurshid’s take on legislative actions
[8:22] – What is the Medical Marijuana Regulation and Safety Act
[10:05] – Khurshid explains the Cole Memo
[11:10] – Khurshid talks about common questions and concerns from clients
[14:01] – Out of state investors that want to invest in the CA cannabis market
[16:44] – Opportunities for new types of business
[20:01] – Khurshid talks about BMMR
[22:04] – Licensing deadlines
[23:41] – Why do raids continue
[30:15] – Khurshid talks about his top of mind issues
[35:40] – Pesticide regulation
[40:52] – Contact details for Greenbridge Law

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