Mass Regulators Remind Registered Agents: “Remain Suitable At All Times”

Cannabis Control Commission instructs licensees to tell them when someone on their team gets in trouble with the law


On Monday, Jan. 13, the Massachusetts Cannabis Control Commission sent a bulletin to all its licensees and their registered agents pertaining to “suitability,” i.e. whether operators or employees have problems with law enforcement that could disqualify them from working in the industry. 

Addressing “all Marijuana Establishments, Medical Marijuana Treatment Centers, and Independent Testing Laboratories,” the memo states, simply, that “all Licensees, Persons or Entities Having Direct or Indirect Control, and Registered Agents are required to remain suitable at all times a License or registration remains in effect.”

The bulletin further notes: “Each individual and entity subject to the suitability tables are independently responsible for notifying the Cannabis Control Commission (Commission) of any charge or conviction of an offense that would result in a Presumptive Negative Suitability Determination or a Mandatory Disqualification within ten days of arrest or summons, and within ten days of the disposition of the merits of the underlying charge.”

The CCC warns: “Individual or entities subject to an event that results in a Presumptive Negative Suitability Determination or Mandatory Disqualification must submit notification via email to Licensing@CCCMass.com. … Failure to make proper notification to the Commission may result in suspension, revocation, or other enforcement action as deemed appropriate.” 

In the event that something goes down, that communication to the CCC should include details such as
“the related License and registration numbers,” “the applicable precipitating issue,” and “a summary of the event.” 

The memo also directed those seeking more information to a table in the state’s cannabis law that breaks down different offenses and the results those would have on an agent’s registration, such as “Mandatory Disqualification” for a “Felony involving violence against a person.”