The Arizona Board of Accountancy issued the following on March 28, 2016:
“The authorized sale of medical marijuana is legal in the State of Arizona and the State of Arizona has mandated that such sale be performed by licensed and regulated medical marijuana dispensaries. Further, the State of Arizona has mandated that to renew their license such medical marijuana dispensaries must retain a certified public accountant to perform an audit of the financial statements of such entity. The Arizona Board of Accountancy recognizes that while the state of Arizona has a law that legalizes the sale of medical marijuana, the Federal Government does not have such a law. As there is a dichotomy between Federal and Arizona law, the Arizona Board of Accountancy can make no determination of how such a conflict might ultimately affect a medical marijuana dispensary or any of its service providers. Hence, the Arizona Board of Accountancy has concluded that during the contemplation of acceptance of any accounting services engagement for a medical marijuana dispensary, an Arizona registrant should diligently evaluate and address the potential risks and uncertainties associated with providing such services. Registrants should carefully consider the criteria provided in auditing standards and other professional materials, as well as professional guidance specifically related to providing services to the medical marijuana industry.
Further, the Arizona Board of Accountancy has concluded that merely accepting an engagement to provide accounting services to a medical marijuana dispensary does not, on its face, constitute an act discreditable to the profession and it will not pursue independent disciplinary action against an Arizona CPA registrant based solely on such acceptance. The Arizona Board of Accountancy recommends that Arizona registrants considering providing services to the medical marijuana industry read the materials referenced herein, professional standards applicable to the professional services to be provided and guidance offered by State and Federal regulatory bodies, including, but not limited to the Internal Revenue Service, the U.S. Department of Justice and the U.S. Securities Exchange Commission and any other authoritative materials available that frame the issues contemplated herein.”