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Payment processing is a problem for dispensaries all over the US. Most merchant service providers avoid this industry for fear of aiding and abetting federal crimes. Unfortunately, this pushes both the state-licensed dispensaries and their registered cardholding patients to rely excessively on physical cash for transactions. This is a problem because it puts everyone, including the general public, at a higher risk for crime, theft and fraud.

transaction processing solutions

Cashless ATM for licensed cannabis dispensaries

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A cashless debit card terminal is a good option for reducing reliance on physical cash: A small, card-reading terminal sits on the counter, and patients simply slide a debit card and enter their PIN number to make a transaction that is deducted from whatever account is linked to the debit card. The process is similar to an ATM.

For a dispensary, the cost of operating the terminal is negligible. And the patient pays only a small, industry-standard, out-of-network fee. Overall the amount of cash on the premises is greatly reduced, which improves the dispensary’s safety and security for both patients and staff.

Cashless ATMs for cannabis dispensaries:

  • Nominal start-up costs
  • Eliminates risks associated with a cash-filled ATM in a lobby or waiting area
  • Fees equal to out-of-network ATM charges – a small expense for the convenience
  • Easy to use card terminals require very little counter space
  • System creates direct electronic bank deposits
  • Increases sales by accommodating impulse purchases

A quick word about traditional ATMs: roughly half of the nation’s 420,000 machines are bank owned – meaning the other half are owned by small companies leasing these machines out.  Many, if not most, ATMS run on Windows XP, which as of April 8 2014 is no longer supported by Microsoft – so there are no patches or security fixes forthcoming.  Once the first XP machine is hacked, none will be safe.

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Why not offer Visa and/or MasterCard?  Because neither company will knowingly process cannabis purchases.  Unscrupulous vendors will set up a client’s payment terminals to miscode transactions as something they are not in order to mislead the card processor.  (By the way, Square is also off-limits.)

dispensary payment method

Cashless ATM terminal

While this may be convenient for customers, it most definitely is not for business operators when said processor discovers the true nature of the business – and they do find out.  Those merchants can then spend months recovering funds being held by a card network.

Additionally, these business owners run the risk of being added to the Terminated Merchant File.  Being “TMF’ed” (aka put on the MATCH List) is to be blacklisted, with one’s name, business name, even Social Security number attached – and it is difficult and time consuming to win removal from this roster.  Few who’ve ever had the experience would try a similar charade again.

One day the credit card companies will provide services.  Until then, patients can swipe their debit cards at cashless ATM terminals to make legal cannabis purchases, while merchants enjoy direct electronic deposits and freedom from the risks associated with being an all-cash business.

Contact US Debit Services | Jon Graves | 855-749-6121 for more information

US Debit Services was created to provide safe, secure and convenient payment processing options to the legal cannabis industry. Our goals are reducing the amount of cash that customers must carry and business owners must handle while providing transparent reporting and accounting for regulators.  US Debit Services systems are currently processing transactions in Arizona, Colorado, Oregon and Washington.

DFPR hiring Administrative Assistant for cannabis pilot program

The State of Illinois, through the Department of Financial and Professional Regulation (DFPR), is hiring an Administrative Assistant to help implement the new medical marijuana law. The position is in a Chicago, Cook County Office and pays $4,159.00 – $6,218.00 monthly. Requires four years of college; preference for applicants who demonstrate working knowledge of the medical cannabis pilot program. Applications are due Sept. 3.

See the job posting: Department of Financial and Professional Regulation (DFPR), Cook County, Administrative Assistant

(If the above link doesn’t work, search job postings on the Work 4 Illinois website for the word “cannabis.”)

Description of Duties: Under general direction, performs administrative functions for the Medical Cannabis Pilot Program Section in accordance with the Medical Cannabis Pilot Program Act and the related rules and regulations; assists in the planning, directing and evaluating of section functions; provides coordinative assistance to management related to the Medical Cannabis Pilot Program Section. Travels to various sites to attend meetings and conferences. Provides technical support to management staff. Assists with special projects; researches problems and conducts various studies.

Minimum Requirements: Requires knowledge, skill and mental development equivalent to completion of four years of college, preferably with courses in public or business administration. Requires one year of professional experience in a public or private organization, or completion of an agency approved professional management training program. Prefers attention to detail, prompt responsiveness to inquiries and requests and a working knowledge of the Medical Cannabis Pilot Program, the policies and procedures of the Department and Division.

Town hall meetings for Illinois’ medical marijuana program concluded this week. Draft applications for cultivation centers and dispensaries were pensive subjects. Questions focused on cannabis packaging, edibles, infused products and fingerprinting.

Journal-Star says “more than 100 people” attended Monday’s forum at Peoria’s public library, and most of their questions sought clarification of regulatory rules and draft applications.

Disclose everything.

A takeaway theme from the Journal-Star is that applicants are better off disclosing more information than too little. If something is questionable, you should explain it. (This is intuitive, not surprising at all, to a highly qualified application writer who is passionate about Illinois medical cannabis law and regulations).

“We prefer more information than less,” [said Bob Morgan, an attorney for the Illinois Department of Public Health and the coordinator of the Medical Cannabis Pilot Program]. “When there’s a question, we prefer more.”

“I would lean toward disclosure… If you don’t know whether to include something, go ahead and include it,” said Ray Watson, general counsel for the Illinois Department of Agriculture. 

Preference for Illinois residents?… Out-of-state experience?

The Journal-Star says lawyers wanted to know if preferential treatment would be given to in-state residents or organizations with cannabis experience in other regulated medical cannabis states.

Several attorneys who spoke referenced either out-of-state clients interested in expanding businesses from other medical marijuana states or home state clients wondering how they could compete against others who already had experience in the trade.

“We try to find an appropriate balance between encouraging those with experience versus those based in Illinois,” Morgan said. “We’re stuck trying to find the most qualified with a limited number of licenses.”

Unlike Colorado, Illinois law does not have an in-state residency requirement for ownership or participation in a licensed medical cannabis business. Regulations make clear that specialized experience related to cannabis medicine is desirable, but it’s difficult to demonstrate legal cannabis experience in Illinois without partnering with or otherwise employing out-of-state talent. A small preference for in-state residents manifests itself in the form of bonus points attainable by showing a company and owners have real ties to the state, such as organizational headquarters and residency.

Packaging of cannabis buds, edibles, infused products?

Chicago Tribune estimates “nearly 300 people” attended Wednesday’s town hall in Chicago. Associated Press says it was “attended by more than 500 people.”

Both newspapers say cannabis packaging at cultivation centers and dispensaries was a focal point of the audience:

Will retailers be able to open a package of marijuana to give customers a whiff?” (is the lead sentence of AP’s article).

“…A lot of people do like to see what they’re buying,” said Roeper, an attendee who asked whether dispensaries will be able to open marijuana packaging to let customers see and smell the product. Illinois requires medical cannabis to be kept in child resistant, light-resistant packaging.

Roeper didn’t get a direct answer, but was told the Illinois rules require that marijuana from an opened package must be disposed of within a week in a way that makes it unusable. Presumably, retailers could open samples for customers to see and smell, then destroy samples each week.

One cannabis packaging company in Illinois is already abreast of the regulations and is providing cultivation centers and dispensaries with help on the Product Safety & Labeling Plan part of their applications. Fisher Container Corp. of Buffalo Grove has a child-resistant, tamper-evident pouch called the MEDI-CRREO which is proving popular among cultivation centers because it is flexible, light-resistant, and tamper-evident. A clever pinch and zip design makes the pouch child-resistant.

Entities providing cultivation services to more than one organization?

According to Associated Press:

A master grower can work for multiple centers, with a caveat: The rules bar a single entity from winning permits for more than three cultivation centers and five dispensaries. If one master grower is named as a principal officer by numerous applicants, that could jeopardize the chances for any one of the applicants, Watson said.

“We’re trying to avoid concentration of permits in too few hands,” Watson said. “If someone is participating in 15 different applications, they may be affecting the ability of those who are applying.”

Avoiding Massachusetts’ problems

Associated Press again:

James Watts, of Firm Systems Fingerprinting, asked whether fingerprint-based background checks would reveal out-of-state convictions. He was told the current system does not, but that applicants will be required to disclose such convictions.

… And please, do disclose and be honest about everything. For you own sake, for the sake of other applicants, for the State of Illinois, for patients, and for the sake of making real social progress with cannabis issues. Illinois can’t afford to end up like Massachusetts.

Andrew Glatz applying for medical cannabis dispensary in Aurora

Andrew Glatz of Crown Height Realty is looking at property in Aurora for a medical cannabis dispensary. A news report indicates Glatz has been communicating with city officials for months but has not submitted a formal proposal to the city.

Glatz told Beacon News:

“This business will be a destination location. Patients will drive two hours to get their medicine,” he said. “I would love to locate in Aurora.”

Aurora dispensary applicant

Glatz and undisclosed California partner want a “destination location” in Wayne and Garth’s town.


Glatz seems nervous about saying who he does business with, except that they are from California.

Glatz declined to confirm the name of his business or his partner, who he says operates medical marijuana dispensaries in California.

Importance of Security Plan

An Associated Press article about the security requirements of dispensaries and cultivation centers is gaining traction this week. According to the article (definitely a must-read):

It will be grown in enclosed, locked facilities. Silent alarms, 24-hour video surveillance and bulletproof glass will safeguard the retail centers where patients with special IDs will be escorted to their cars after buying pot.

That’s the flinty picture painted by business owners competing for a limited number of marijuana cultivation and dispensary permits under the state’s new law. A detailed security plan will give an edge in the scoring, so many of the applicants say they’re exceeding the law’s already-strict requirements.


Cultivation center security plan

Laws of nature let cannabis grow everywhere. Laws of man say here only.

With banks hesitant to serve the industry because of federal law, marijuana businesses in Colorado and elsewhere deal mostly in currency. It’s unclear whether Illinois banks will provide their services.

Illinois requires cultivation centers to have 24-hour closed-circuit television surveillance of all entrances and exits, parking lots, alleys and the entire inside of the facility, except for restrooms and the executive office.

Time-stamped recorded video must be kept for 90 days on site and another 90 days off site. Each center must have a printer capable of immediately producing a clear still photo from video. Dispensaries have similar requirements.


The costs involved in launching a cultivation center in Illinois are extravagant. An applicant bears large expenses even if a license is not ultimately won. Some of these costs pay for service professionals like lawyers, consultants, architects, engineers, and lobbyists.

Illinois Times, a free weekly paper in Springfield, explores start-up costs for an Illinois cannabis company:

expensiveWith the state setting up steep financial barriers to entry, it is not a business for just anyone. The application fee for a single cultivation center – there will be 21 – is $25,000, with the lucky winners having the privilege of paying a $200,000 license fee for the first year of operation and $100,000 per year after that. The state is also requiring cultivation center operators to demonstrate they have $500,000 in liquid assets, and they must also post $2 million surety bonds for each center.

There will be 60 dispensaries where marijuana will be sold to patients to serve the entire state, a fraction of the number within Denver or Los Angeles or other cities where marijuana, medical or otherwise, has long been legal under state statutes. The state is charging $5,000 to apply for a dispensary license, plus a $30,000 annual license fee (reduced to $25,000 after the first year), and operators must post $50,000 surety bonds and show that they have $400,000 in liquid assets.

Christopher Stone, lobbyist: three cultivation, three dispensary applications

For at least one group applying for licenses, the start-up costs may entail keeping a lobbyist on the payroll. The Illinois Times article identifies Christopher Stone, “a Springfield lobbyist who is working with a group of potential investors that hopes to win licenses for three cultivation centers and an equal number of dispensaries.” 

According to the website of Christopher Stone’s Company, Governmental Consulting Solutions, he has served as:

Executive Director of the Association of Illinois Soil and Water Conservation Districts, representing the association’s interests both in Illinois and Washington, D.C. and overseeing all of the day-to-day management needs of the organization;

moneybagsDirector of Governmental Affairs for Wine & Spirits Distributors of Illinois, managing the governmental affairs activities for a $1.4 billion industry, advocating for the membership’s needs before media, legislative and regulatory agencies, and assisting the four largest members in the development of new economic development programs;

Director of Governmental Affairs for Romano Brothers Beverage Company, developing a comprehensive governmental affairs program for the $400 million company and managing its legislative, political and economic development programs within the City of Chicago and the State of Illinois; and

Legislative & Policy Analyst for the Speaker of the Illinois House.

As for the group Stone represents in applying for the licenses, Illinois Times writes:

All told, Stone says that his group is prepared to spend more than $10 million on license fees and applications and bonds to get into the nascent marijuana industry. Why?

“Generally, when you’re first in a deal, you tend to make money,” Stone says.

Tactical Security LLC of Waukegan, is a locally-owned, Illinois-licensed private security agency that writes security plans for medical cannabis dispensaries, cultivation centers, and transportation. Since 2007, our team of experienced law enforcement and security professionals has been ensuring the safety of clients, currency and property throughout metro Chicago and Cook, Lake, DuPage, McHenry, Kane, DeKalb, Boone, Winnebago, Stephenson, and Jo Daviess Counties.

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Tactical Security plans are tailored to the unique needs of each facility

Tactical Security LLC provides comprehensive security planning for cultivation center and dispensary applicants. Our experienced law enforcement and security professionals have closely studied the Medical Cannabis Pilot Program Act and subsequent regulations administered by the Department of Agriculture and Department of Financial and Professional Regulation (DFPR). We are more than prepared to meet and exceed the rigorous security requirements involved in protecting marijuana facilities and transporation.

cannabis security plan

Tactical Security plans for Illinois medical cannabis industry

And because Tactical Security has years of experience providing security in Illinois, we understand precisely what the State’s regulatory agencies are looking for in a successful application. We will reach for every possible point on the security plan part of your application. Our comprehensive services entail closely scrutinizing your facility design and advising how best to deploy all of the application’s required security measures. We will help you understand all of your options for video surveillance hardware, software, equipment, security vehicles, and service packages. And most importantly, we will deliver a sophisticated written security plan that is tailored to the exact specifications of your facility. This is what you must submit to the regulatory agency for ultimate review by Illinois State Police.

Tactical Security for cultivation centers

Our law enforcement and security professionals tailor security plans to fit all compliance requirements of a cultivation center facility as required by law and regulations. This includes:

  • Description of “enclosed locked facility” and the areas used to store or secure cannabis.
  • Employee management and oversight guidance.
  • Facility access controls.
  • Perimeter intrusion detection and alarm systems.
  • Personnel identification systems.
  • Electronic 24-hour surveillance system to monitor interior and exterior of facility, accessible in real-time to DFPR and authorized law enforcement officers.
  • Fully operational security alarm system.
  • Safe, vault, and other equipment guidance and acquisition.
  • Demonstration of ability to prevent theft and diversion.
  • Transportation plan including procedures for safely and securely delivering cannabis medicine and currency to registered dispensaries.

Tactical Security’s knowledge of Illinois terrain is critical to transportation plan

When it comes to transportation, Tactical Security has a fundamental understanding of Illinois that out-of-state contractors simply cannot provide. We know the streets, highways and backroads of Illinois and its cities. We know criminal methods and local high-risk areas, and we take proactive steps to foresee and avoid them.

Tactical Security supplies:

  • Vehicles that are ideal for transporting cannabis and currency.
  • Randomized transportation routes and schedules that avoid high risk times and areas.
  • Trained, experienced security personnel to drive the vehicle.
  • Equipment for secure communication between security vehicle and cultivation center.

Tactical Security for dispensaries

Our law enforcement and security professionals tailor security plans to fit all compliance requirements of a dispensary facility as required by law and regulations. This includes:

  • Cannabis transportation security

    Tactical Security’s MM Division protects dispensaries and cultivation centers.

    Smart, compliant designation between restricted access areas, limited access areas, and customer floor space.

  • Security measures to prevent entry into and theft from restricted access areas.
  • Smart locks, storage, safe and vault facilities and design.
  • Locked door or barrier between facility’s entrance and limited access area.
  • Plan for preventing individuals from remaining on premises if they are not permitted by law or regulation.
  • Development of policy for maximum capacity and patient flow in waiting room and patient care areas.
  • Perimeter alarm on all entry points and perimeter windows.
  • Failure notification system that provides an audible, text or visual notification of any failure in the surveillance system.
  • Duress alarm, panic button and alarm, holdup alarm or after hours intrusion detection alarm that will notify the Public Safety Answering Point (PSAP) for the law enforcement agency having primary jurisdiction.
  • Unobstructed video surveillance of all enclosed dispensary areas, including all points of entry and exit that shall be appropriate for the normal lighting conditions of the area under surveillance.
  • Unobstructed surveillance of outside areas.
  • 24-hour recordings from all video cameras.
  • Ability to remain operational during a power outage and ensure all access doors are not solely controlled by an electronic access panel to ensure that locks are not released during a power outage.
  • Plan for prohibiting accessibility of security measures including combination numbers, passwords or electronic or biometric security systems to persons other than specifically authorized agents.
  • Protocol for unloading shipments arriving from a cultivation center.
  • Sufficient lighting of outside perimeter to facilitate surveillance.
  • Ensuring that no trees, bushes and other foliage allow for a person to conceal themselves from sight.
  • Emergency policies and procedures for securing all product and currency following any instance of diversion, theft or loss of cannabis.

Tactical Security is an Illinois company employing American veterans

Implicit in the Ag Dept. and DFPR regulations is a concern for Illinois’ economy and environment. The regulations allow applicants to obtain bonus points by demonstrating a Community Benefits Plan, a Local Community/Neighborhood Report, and an Environmental Plan (Ag Dept Regulations Section 1000.110(c), DFPR Regulations Section 1290.70(d)). Your application writer may be able to reach for bonus points by demonstrating Tactical Security’s commitment to hiring Illinois residents and to sourcing security solutions that originate in Illinois. We are also passionate about taking care of our returning troops from Iraq and Afghanistan, many of whom are perfectly trained for protecting security transport vehicles containing cannabis and currency.

Contact Tactical Security LLC at are Waukegan, Illinois office: (847) 263-1900.


3C Compassionate Care is applying for cannabis dispensary permits in Naperville and Joliet, Illinois. Proprietors of the company are Hugo and Traci Fernandez, Kathy Tucker and Will County Circuit Judge Robert Livas. 3C Compasionate Care promises to deliver 25% of profits to charity and local communities.

3C Compassionate Care3C Compassionate Care has a website where you can learn about their plans to open dispensaries in Naperville and Joliet.

There is also an informative article from Chicago Tribune:

Hugo and Traci Fernandez have proposed a facility at 1701 Quincy Ave. drawing on their own personal experience with neurological conditions. They are hoping the state will grant them a license later this year.

The couple already runs both an Internet marketing agency and a nonprofit group, the United Paralysis Foundation. The latter stemmed from Traci Fernandez’s battle with transverse myelitis, a neurological disorder she contracted in 2008 that left her paralyzed. The foundation funds research for paralysis and spinal cord injuries.


3C Dispensary Naperville, Joliet

Meet 3C Compassionate Care’s executive team

3C Compassionate Care’s biographical information and credentials are displayed on their website. Hugo Fernandez is CEO, Kathy Tucker is COO, Traci Fernandez is Compliance Officer, and Judge Robert Livas is Security Officer.

The company expects to have such a successful business that it is promising 25% of profits away:

They are pledging 20 percent of the profits to their foundation and another 5 percent to the local communities where they run dispensaries. In addition to opening a Naperville dispensary, the company hopes to open one in Joliet.

The company’s planned location in Joliet is in the Rock Run Business Park.

If you’re applying for a dispensary or cultivation center permit in Illinois, then a licensed Illinois lawyer should be part of your business planning and development team. The Compassionate Use of Medical Cannabis Pilot Program Act and subsequent regulations create a highly complex regulatory framework for which compliance must be demonstrated in painstaking detail. An attorney is the only type of professional with the necessary knowledge, training, and experience to undertake the application writing process.

Absolute compliance must be planned for and demonstrated in an Illinois cultivation center permit application. In addition to the new medical marijuana law and regulations, a winning permit application must demonstrate that the cultivation center management team has knowledge of and has planned for compliance with all other applicable laws and regulations.

For example, a cultivation center business plan must demonstrate compliance with the following federal laws and regulations:

  • Federal Food, Drug, and Cosmetic Act (21 USCA 301)
  • Federal Fair Packaging and Labeling Act (15 USCA 1451)
  • Tolerances and Exceptions for Pesticide Chemical Residues in Food (40 CFR 180)

A cultivation center permit application must also demonstrate compliance with many Illinois laws:

  • Compassionate Use of Medical Cannabis Pilot Program Act (410 ILCS 130)
  • Administrative Review Law (Article III of the Code of Civil Procedure)(735 ILCS 5/Art. III)
  • Cannabis Control Act (720 ILCS 550)
  • Controlled Substances Act (720 ILCS 570)
  • Food, Drug and Cosmetic Act (410 ILCS 620)
  • Food Handling Regulation Enforcement Act (410 ILCS 625)
  • Sanitary Food Preparation Act (410 ILCS 650)
  • Uniform Conviction Information Act (20 ILCS 2635)
  • Private Detective, Private Alarm, Private Security, Fingerprint Vendor, and Locksmith Act of 2004 (225 ILCS 447)
  • Illinois Vehicle Code (625 ILCS 5)
  • Criminal Code of 2012 (720 ILCS 5)
  • Rights of Crime Victims and Witnesses Act (725 ILCS 120)
  • Code of Civil Procedure (735 ILCS 5)
  • Probate Act of 1975 (755 ILCS 5)
  • Illinois Environmental Protection Act (415 ILCS 5) and associated administrative rules

An Illinois cultivation center application must also demonstrate appropriate planning and compliance with various Illinois administrative rules:

  • Illinois Food, Drug and Cosmetic Act (77 Ill. Adm. Code 720)
  • Manufacturing, Processing, Packing or Holding of Food Code (77 Ill. Adm. Code 730)
  • Food Service Sanitation Code (77 Ill. Adm. Code 750)
  • Title 20, Section 1265.30 of Electronic Transmission of Fingerprint Requirements
  • Illinois Environmental Protection Agency Technical Policy Statement (35 Ill. Adm. Code 651 and 653)
  • Illinois Plumbing Code (77 Ill. Adm. Code 890)

DFPR answers FAQs for cannabis dispensaries

Illinois Department of Financial and Professional Regulation has posted a set of frequently asked questions and answers for prospective dispensary license applicants. Generally the FAQs address basic dispensary requirements and the administrative rulemaking process.

Regarding its potential timetable for completing regulations, the agency says:

DFPR has 120 days from January 1, 2014 to file administrative rules with the Joint Committee on Administrative Rules (JCAR). There will then be a First Notice period that lasts a minimum of 45 days. After the First Notice period, there will be a Second Notice period that lasts for a maximum of 45 days with the possibility of a 45 day extension. Once the administrative rules are adopted, DFPR will establish the application process for dispensing organizations.

You can view the FAQs for Illinois dispensaries on DFPR’s website.

Sophisticated information for Illinois cannabis dispensaries

If you find DFPR’s short list of FAQs less than satisfying, please check out this book available on Amazon. Written by an Illinois attorney with expertise in analyzing legislation and regulations, the book features in-depth chapters designed to guide individuals who want to invest in or manage Illinois cultivation centers and dispensaries. The book is without a doubt the quickest and cheapest way to gain advanced working knowledge of the law so that you can begin making plans now, well ahead of the regulations.

The book’s chapter on dispensaries spans 25 pages and is organized into the following subjects:

  • Functions of a dispensary
  • 60 dispensaries, reasonably dispersed
  • Market constraints
  • Location restrictions
  • Security
  • Products and services for sale
  • Interacting with patients and caregivers
  • Employees
  • Principal officers and board members
  • Applying to become a dispensary
  • Ongoing Legal Compliance

Chicago’s plan for controlling the location of medical marijuana businesses would allow cultivation centers and dispensaries to be located only in areas zoned as manufacturing districts. The plan has the support of Mayor Rahm Emanuel and Chairman Ed Burke of the Department of Housing and Economic Development (HED).

If Chicago’s City Council approves the plan, prospective  dispensaries and cultivation centers will have to apply for special use permits through the City’s Zoning Board of Appeals. Prospective operators must locate in manufacturing zones, and they must reserve minimum parking space requirements based upon the size of their facilities. (Mayor’s office press release here).

The City’s Bureau of Planning and Zoning provides an excellent zoning map of Chicago where you can get information about potential facility locations. The text of Chicago’s Zoning and Land Use Ordinances are also available online.

Chicago’s proposed location restrictions are in addition to those already imposed by the State of Illinois’ Compassionate Use of Medical Cannabis Pilot Program Act. The law prohibits cultivation centers from being located within 2500 feet (a half mile) of schools, child care facilities, and areas zoned for residential use. The law also prohibits dispensaries from being located within 1000 feet of schools and child care facilities. These rules are applicable in the City of Chicago.

Plus there are two other huge restrictions imposed by law. First, there can be no more than one cultivation center in each state police district. The City of Chicago is itself a single State Police District, which means only one cultivation center can be located in Chicago. However, there is a bill in the legislature which would amend the law to allow a State Police District to have more than one cultivation center, but no more than two. These amendments have a good chance of passing because they have been attached to relatively uncontroversial  internet lottery legislation (SB 1955) which has already been approved by one chamber of the legislature.

Second, regarding dispensaries, the law requires that up to 60 of them be:

“Geographically dispersed throughout the state to allow all registered qualifying patients reasonable proximity and access to a dispensary.” Section 155(a).

Illinois is a relatively large state, and much of the southern 2/3 of it is rural. But assuming there is as much interest in the southern part of the state as there is in Chicago, the Department of Financial and Professional Regulation may be able to grant only so many dispensary registrations to operators in Chicago.

Are you planning a cultivation center or dispensary? Check out this new book: Illinois Medical Marijuana Law: A Practical Guide for Everyone. It’s a handy reference guide you should keep by your side over the coming months. Get a head start on the competition before the regulations come into effect. Kindle/tablet version also available.

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