What this page covers

• How many armored cash pickups a dispensary should schedule
• What happens if you hold too much cash on site
• Why banks require armored transport contracts
• What banks review in your cash logs
• What happens when deposits do not match in-store totals
• When discrepancies can escalate into AML concern

Why cash handling is a banking risk, not just a security issue

New York dispensaries operate in a federally sensitive environment.

Because cannabis remains illegal under federal law, banks that serve dispensaries must follow strict anti-money laundering requirements under federal banking law.

That means banks monitor:

• Deposit patterns
• Cash accumulation
• Transport procedures
• Internal controls
• Reconciliation accuracy

Cash behavior that looks irregular can trigger review.

This is not about suspicion of crime.
It is about regulatory compliance.

How Many Cash Pickups Should a Dispensary Have Per Week?

There is no fixed legal number

There is no New York statute that mandates a specific pickup frequency.

However, banks and armored carriers expect pickup frequency to align with:

• Weekly revenue
• Vault capacity
• Insurance limits
• Deposit consistency
• Your declared underwriting profile

If your weekly revenue supports it, most dispensaries schedule:

• 2 to 5 pickups per week

High-volume locations may require daily pickups.

What happens if you hold too much cash on site?

Holding excessive cash creates three separate risks:

1. Insurance Risk

Insurance policies typically cap in-store cash coverage.
If you exceed insured vault limits, uncovered losses may not be reimbursed.

2. Safety Risk

Higher on-site volume increases robbery risk and employee exposure.

3. Banking Risk

Banks model expected deposit frequency.
If deposits slow while revenue stays steady, that creates pattern deviation.

Banks do not like unexplained pattern breaks.

Liquidity timing matters

Operators often overlook timing.

Questions banks indirectly consider:

• Are rent and payroll being paid on schedule?
• Are vendor payments consistent?
• Are deposits aligned with sales volume?

If you are holding large cash balances while delaying deposits, your activity profile changes.

Consistency protects you.

Why Your Bank Requires an Armored Transport Contract

Banks serving cannabis businesses face federal oversight.

They verify armored transport contracts to confirm:

• Licensed carrier is used
• Pickup schedule is predictable
• Insured transport limits are adequate
• Chain-of-custody procedures exist
• Cash handling risk is controlled

Without a contract, a bank may view operations as unmanaged risk.

If you do not have an armored carrier agreement, that is typically a red flag.

What banks review in the contract

Banks typically confirm:

• Carrier licensing
• Pickup frequency
• Maximum insured transport amounts
• Documentation procedures
• Contract validity dates

They may also compare your declared pickup frequency to your actual deposit patterns.

If those differ, questions arise.

What Banks Actually Review in Your Cash Logs

Banks are not reviewing your logs casually.

They are reviewing them because regulators require ongoing monitoring.

They examine:

• Drawer totals
• End-of-day vault counts
• Pickup receipts
• Bank deposit confirmations
• Pattern consistency over time

They are not looking for perfection.

They are looking for predictable behavior.

What Happens If In-Store Totals Don’t Match Bank Deposits?

Occasional discrepancies

Minor human error happens.

Small discrepancies that are corrected quickly with documentation usually do not escalate.

Repeated discrepancies

Repeated mismatch between:

• POS sales totals
• Cash drawer counts
• Vault totals
• Bank deposits

can trigger internal bank review.

Banks may interpret repeated discrepancies as:

• Weak internal controls
• Potential diversion
• AML risk exposure

When escalation becomes possible

If discrepancies are:

• Large
• Repeated
• Unexplained
• Paired with unusual deposit timing

A bank may escalate internally.

Under federal anti-money laundering rules, banks must file Suspicious Activity Reports in certain situations.

Operators are not notified when a SAR is filed.

Reconciliation is not optional in cannabis.

Why reconciliation must be daily

Daily reconciliation protects you from:

• Shrink
• Internal theft
• Accounting drift
• Regulatory exposure
• Banking suspicion

In cannabis retail, three numbers must align:

• POS reported revenue
• Physical cash counted
• Bank deposit recorded

They do not have to be identical to the dollar every day.

But persistent divergence creates risk.

Common operator mistakes

• Skipping pickups to save cost
• Making large lump-sum deposits after holding cash
• Changing pickup frequency without notifying the bank
• Switching armored vendors without documentation
• Delaying reconciliation until week’s end
• Allowing vault balances to exceed insured limits

None of these are crimes.

But they change your risk profile.

When does cash become a banking problem?

Cash becomes a banking problem when:

• Volume deviates from your underwriting profile
• Deposit timing becomes irregular
• Discrepancies repeat
• Controls appear weak
• Growth is not proactively disclosed

Banks manage regulatory risk.

If your behavior changes, their risk assessment changes.

What to implement now

• Match pickup frequency to revenue
• Confirm vault insurance limits
• Maintain written chain-of-custody procedures
• Reconcile daily
• Notify bank of significant revenue growth
• Keep armored transport contract current
• Document discrepancies immediately

Predictability protects your banking relationship.

Source material

• Bank Secrecy Act (31 U.S.C. § 5311 et seq.)
• FinCEN Guidance Regarding Marijuana-Related Businesses (FIN-2014-G001)
• Federal anti-money laundering regulations (31 C.F.R. Chapter X)
• Standard armored transport industry licensing FAQ