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StaffStaffOctober 15, 2019


Canopy Growth Corporation (NYSE: CGC) stock jumped over 7% on news that the company sold its 42,087,639 shares in Australian cannabis company AusCann Group Holdings (AusCann) via an off-market block trade at $0.15 per share for gross proceeds of $6.3 million. The trade was facilitated by Canaccord Australia. The stock was lately trading at $20.32. The sale represents Canopy Growth’s total 13.2% interest in AusCann.

“Canopy Growth remains optimistic about the future of the Australian medical cannabis market and will continue to collaborate with the team at Auscann to support greater physician understanding and patient access to high quality cannabis products throughout Australia,” said Mark Zekulin, CEO, Canopy Growth. “The decision to divest our position in AusCann, which we obtained three years ago in exchange for support provided, will allow us to sharpen our focus on our wholly-owned operations in the market, while continuing to collaborate with our partners at AusCann.”

Dr. Marcel Bonn-Miller, Canopy Growth’s Global Senior Director of Clinical Science, will continue to sit on the AusCann Board of Directors to facilitate future collaboration.

Beckley Deal Closes

Canopy also said that it closed the previously announced acquisition of the cannabinoid based research company Beckley Canopy Therapeutics, including the joint commercial venture Spectrum Biomedical UK. The company said that the teams will now be integrated into the broader Spectrum Therapeutics organization to increase the breadth of the clinical research being pursued under the Spectrum banner and to combine continental European and the United Kingdom commercial teams.

“The acquisition comes at a time when commercial opportunities across Europe are ramping up,” said Mark Zekulin, CEO, Canopy Growth. “Spectrum Biomedical has completed all necessary approvals to import cannabis into the UK market and is proud to facilitate patient access to safe cannabinoid-based medicines there. Consolidating our UK-based operations will allow Canopy to simultaneously improve its research and commercial capabilities across the continent.”

Beckley Canopy was formed as a joint venture in January 2018 between Beckley Research & Innovations and Canopy Growth to research and develop clinically validated cannabis-based medicines, with a strong focus on intellectual property protection. The research platform combined European and North American-based leaders in cannabis research from BRI and Canopy Growth to create a strong and complementary UK-based European partnership. Since its inception, Beckley Canopy has made significant progress in its core research areas, added additional indications of interest, and worked closely and in a complementary fashion with the global Canopy research team.

Debra BorchardtDebra BorchardtOctober 15, 2019


Cannabis tech company Flowhub has raised an oversubscribed $23 million Series A financing round led by, Evolv Ventures — the venture fund backed by Kraft Heinz —  and Poseidon, with contributions from investors 9Yards Capital, former NBA commissioner David Stern and Iqram Magdon-Ismail, the co-founder and former CEO of Venmo, among others.

Evolv Ventures’ goal is to invest in new tech companies innovating within the food industry. The firm was created to help Kraft Heinz stay on top of the food industry’s changing trends. However, it isn’t limited to food investing and also looks at new consumer models and consumer insights.

The Flowhub platform is used by dispensaries making it easier for them to run their operations. Some of the features include the Stash app, a mobile inventory management solution, the Cashier app for enhanced front-of-house point-of-sale capabilities with iPad/tablet compatibility, and Order Ahead with integration partner Dutchie for a streamlined in-store pickup process. Flowhub said it also added new technology integrations with LeafBuyer and Leafly as part of its commitment to creating a robust partner ecosystem that enables customers to build their own custom cannabis tool stack.

“What we are experiencing right now is an end to cannabis prohibition and Flowhub is on the front lines of this movement,” said Kyle Sherman, founder and CEO, Flowhub. “Every legal transaction completed with the Flowhub retail platform is a positive step forward, and we are committed to helping our customers build thriving cannabis businesses. With this investment, we will continue to automate the cannabis supply chain, retail and reporting processes and bring to market technology solutions that are not only shaping the cannabis retail business, but also driving forward the future of legalization and de-stigmatization.”

“We are excited to join Flowhub at such a crucial time in the company’s overall growth journey,” said Jett Fein, partner, “As the demand for legal cannabis products rises across the U.S., Flowhub is focused on using technology to advance the future of the cannabis industry and has built a cloud platform with a suite of applications that enables dispensaries to provide superior and tailored consumer retail experiences in this highly regulated industry.” According to Tech Crunch, the firm  is a 20-year-old, early-stage venture outfit that has raised $400 million in fresh capital across two new funds: a $225 million U.S.-focused fund that’s based in San Francisco, and a $175 million fund that’s focused on Europe and based in Berlin.

Flowhub has experienced tremendous growth over the last year, increasing revenue by 200 percent and doubling its customer base across 11 markets, which includes household brands like Cookies, Dr. Greenthumb’s, Green Dragon, Nectar and Starbuds. The company also added strategic roles to its executive team — including SaaS enterprise tech leader Dave Smith as CRO — grew its female leadership across key strategic business roles such as marketing, product management and finance and has already increased headcount by 50 percent in 2019. Flowhub also recently announced its new headquarters at the former Slack HQ near downtown Denver’s Union Station and three satellite offices to support continued expansion efforts.

“Cannabis is not an industry that you just jump right into,” said Emily Paxhia, managing director, Poseidon. “The compliance and regulation aspects make this a unique industry and Flowhub is one of the leading cannabis tech companies that is taking a meticulous and strategic approach. We saw the potential for Flowhub’s technology and mission early on and we’re thrilled to continue to support them in delivering the cannabis retail experience of the future.”

The $23 million of financing closed on this round brings the company’s total funding to $27 million. This marks the first cannabis tech investment from round leaders Evolv Ventures and and is indicative of the increased appetite to bet big on a maturing market segment with an industry leader like Flowhub. With this injection of capital, the company will continue to invest in product innovation, hire top technical talent and expand its partner ecosystem with future technology integrations and collaborations through an open API approach.

Debra BorchardtDebra BorchardtOctober 15, 2019


Aphria Inc. (TSX: APHA)(NYSE: APHA) stock jumped over 16% to trade at approximately $5.10 in early trading after the company reported that its revenue increased 849% to $126.1 million for the first quarter ending August 31, 2019, however sales declined 2% from the previous quarter. Adult-use cannabis accounted for $20 million in revenue for the first quarter, an 8% sequential increase.

The company delivered net income of $16.4 million in the first quarter. It also stated that it ended the quarter with a strong balance sheet and liquidity, including $464.3 million of cash, cash equivalents, and liquid marketable securities, to fund planned Canadian and International growth.

“We are pleased to report a second consecutive quarter of profitable growth with a strong contribution from our Canadian cannabis operations. Our success was also driven by our international business and the strength and growth of our brands, particularly Broken Coast, despite a small fire at our British Columbia facility at the end of the quarter. This solid start to the year keeps us on track to achieve our fiscal year 2020 financial outlook,” stated Irwin D. Simon. “Going forward, we remain focused on our highest-return priorities both in Canada and internationally as our team furthers the development of our medical and adult-use cannabis brands to drive growth through innovation and return value to shareholders.”

The good news from Aphria lifted the sector, which has been in a bear market for months. Several big names like Canopy Growth (CGC), Tilray (TLRY) and Aurora Cannabis (ACB) were moving higher in early trading by 2-3%. Aphria was also stung by news last week that Aleafia would no longer buy its cannabis saying the company couldn’t meet its supply agreements. So, this was a welcome relief for shareholders.

Revenue Mix

The sequential drop in revenue was attributed to “a decrease in distribution revenue from $99.2 million to $95.3 million associated with a change in business strategy at CC Pharma to maximize profitability after recent changes in the German government’s medical reimbursement model. The decrease in distribution revenue was partially offset by an increase in net cannabis revenue of $30.8 million from $28.6 million.” Aphria said it sold over 3,317-kilogram equivalents in the adult-use market and 1,354-kilogram equivalents for medical cannabis sales. The company also stated that the estimates for the impact on revenue from the small fire at Broken Coast would be approximately $1.5 million in the quarter; however, the majority of the lost quarterly revenue would be reported in the company’s second quarter.

The average retail selling price of medical cannabis fell to $7.56 per gram in the quarter versus $7.66 in the prior quarter, primarily related to a higher percentage of total medical sales coming from Aphria. The average selling price of adult-use cannabis, before excise tax, increased to $6.02 per gram in the quarter, compared to $5.73 per gram in the prior quarter.

Looking Ahead

Aphria is reaffirmed its guidance for fiscal year 2020 with net revenue of approximately $650 million to $700 million, with distribution revenue representing slightly more than half of the total net revenue. The company also forecasted adjusted EBITDA of approximately $88 million to $95 million.

Video StaffVideo StaffOctober 15, 2019


Legion M is a fan-owned company. Its latest project is the Jay & Silent Bob Reboot movie from director Kevin Smith. The dynamic duo head to Hollywood to stop a reboot of their movie. It contains lots of cannabis humor as well.  The movie was released along with the launch of Jay & Silent Bob’s Private Stash cannabis strains, which is available to buy in California with plans to expand to other states.

Subscribe to our channel so we can make more videos.

Anne-Marie FischerAnne-Marie FischerOctober 15, 2019


When David Nikzad first moved to Hawaii in the early 2000s as a proud and confident member of the cannabis industry, he met a shaman who changed his trajectory forever. “Go back to the land,” said the shaman, “We are all children of the land.”

And that is exactly what David Nikzad did.

Using the land of the Hawaiian Islands as his plant-medicine laboratory, Nikzad went on a journey of discovery by spending time with plant-healers, shamans, plant growers, and people in Hawaii who had been using the medicines of the earth through hundreds of years of tradition. “On the Hawaiian Islands, people make ‘brews’ from the almost 2000 botanicals that can be found in the region,” he describes. 

During this journey of discovery, Nikzad found psilocybin, beginning on the path that would eventually lead to him becoming founder of Orthogonal Thinker, a biotech holdings company that now has a goal to bring psilocybin to the world, one microdose at a time.

The Growing Interests in Psilocybin 

Psilocybin can be found in over 100 mushroom species, but is most commonly found in Psilocybe cubensis, or what has become widely known as “magic mushrooms”. When psilocybin is ingested, it’s broken down to produce psilocin, which is responsible for the psychoactive effects. Psilocin is also the precursor molecule of psilocybin. 

The psychedelics movement is moving forward, albeit slowly, with emergent research supporting the therapeutic properties of psilocybin and psilocin, especially among treatment-resistant depression and other mental health issues. 

At present, it is illegal to sell products with psilocybin or psilocin, but just this past year, Denver, Colorado, and Oakland, California decriminalized the possession of products containing these compounds. “I believe that people will have access to these medicines by 2020,” says Nikzad, “There are emergent initiatives going on behind the scenes. This is a global movement.”

The Story Behind Orthogonal Thinker

“I grew up being told I had every mental disorder possible,” said Nikzad when Green Market Report asked him to describe his journey into Orthogonal Thinker. “About 11 years ago, I found myself somewhat depressed with the business world and I began understanding that everything about making money was wrong. Through that process, we started working on a personal fund that was focused on investing in a frequency of energy, which always came down to the founder.”

When he made the move to Hawaii and began meeting with shamans and what he calls “master formulators” of plant medicines, this is when he discovered psilocybin. With his personal investment fund that he’d developed with his business partner, he focused on “incubating plant-medicine companies that used whole-plant products to heal people”. 

“In our 10-year journey, we’ve discerned and identified a ‘nano-super compound’, psilocybin. This is something that can be taken in a microdose, and through Orthological Thinker, we created a product where the effects are not overwhelming, and that is clean. It’s a product that everyone can take.”

Taking a Giant Leap Forward 

Orthogonal Thinker announced last month that it raised $2.5 million in capital. This funding completes approximately $4 million in seed capital raised to date, with more funding coming in.

Orthogonal will use this financing to support the distribution and development of new products across its family of companies, including subsidiaries and Maui Raw. is a formulations company that holds the intellectual property rights for plant-based psychoactive compounds. Maui Raw is a clean-food CPG company committed to delivering non-GMO raw food products. Over the last 10 years, Orthogonal has acquired and developed products supporting new food, technology, and scientific advancements in plant medicine to elevate and empower humanity. 

The choice of partnerships demonstrates that Nikzad is just as empowered by non-psychoactive plant-based compounds for their nutritional properties, as he is the psychoactive ones for their effects. “Nutritional alkaloids need to effortlessly get into our daily diet,” he says. Orthogonal Thinker’s co-founder Michelle Valentin is a food scientist with a background in clean-label foods, taking the approach of food being medicine. 

“Our products are 99% clean label,” says Nikzad, “We look at everything as a delivery system.” Valentin believes that gut health is at the core of food science, with the gut bacteria rebooting in our systems every 9 hours. The products, which are delivered in water-soluble pouches, have been formulated with gut bacteria to promote this process. 

Brining ohana to the Vision 

Orthogonal Thinker’s goal is to make plant-based products that “aid in mental thought and intellectual expansion” accessible to everyone, with a business model that supports providing a three-milligram microdose of the product Psilly for $1. This model is based on the Hawaiian word ohana which to Nikzad means family and friends and never leaving anyone behind. 

“We know this product is very inexpensive to make the way we make it,” says Nikzad, “We understand that with clinical trials and production at a medical-grade, we would still make money, and people would have access.” 

This selfless quality is what makes Orthogonal Thinker stand out. The company is dedicated to open-source IP sharing to ensure that the benefits of psilocin are widespread. “We are in the process of patenting everything we are working on to distribute everything we have to the world,” says Nikzad, “We partner with the best of the best to share IP and information.” Nikzad notes that he has received vast interest from other countries in his work. 

The team that Nikzad has built is critical not only to the financing of the project but also to advancing the movement of psychedelics across the U.S. and the world. “There is an overflow of people who want to work with us. It’s been very humbling,” says Nikzad of the group of investors that includes cryptocurrency investors, venture capitalists, pro athletes, and even one Olympic athlete.  “All our investors have a story too,” he adds.

“Our team is made up of people who have been in the FDA space for 30 years, doctors, chemists, lawyers, and people who once had ‘human jobs’ and are now living their dharma, their purpose in life,” Nikzad adds that it’s important to him that everyone who invests in or works for Orthogonal Thinker has a relationship with plant-medicine and their products. 

“A New Standard of Pharma”

When Green Market Report asked Nikzad whether the cannabis movement has set the stage for the success of the psychedelics movement, he said, “In some regards, cannabis has been a gateway, but has taught us what not to do, and where to shift. We focus on compliance and medical efficacy.”

Nikzad describes what Orthogonal Thinker is doing as the “new standard of pharma”, seeing a future where physicians will be confident in prescribing products like Psilly to their patients. “These are beautiful medicines that are plant-based,” he says, “These are not synthetic products or ‘designer drugs’ this is all about plant medicine nutraceuticals where you’re getting the benefits of whole plant alkaloids.” 

A daily microdoser himself, Nikzad believes wholeheartedly in the benefits of psilocin for health and wellbeing, “This product is in my bloodstream and it makes me operate from a place of empathy, with an open heart and mind.”: a lot more of what the world could use these days. 


Sean HockingSean HockingOctober 15, 2019

If you wish to re-publish this story please do so with the following accreditation
AUTHOR:  aBIZinaBOX Inc. CPAs – Jordan S. Zoot, CPA

California Repeals 280E for Personal Income Tax – Existing law, the Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA), among other things, consolidates the licensure and regulation of commercial medicinal and adult-use cannabis activities and authorizes persons to conduct specified commercial cannabis activities, as defined, in the state.

The Personal Income Tax Law and the Corporation Tax Law allow various deductions in computing the income that is subject to the taxes imposed by those laws. The Personal Income Tax Law conforms as of a specified date to federal income tax laws with respect to itemized deductions, including business deductions and items not deductible, except as specifically provided. The Corporation Tax Law does not conform to those federal income tax provisions but specifically provides for deductions for purposes of that law.

Existing federal income tax laws disallow a deduction or credit for business expenses of a trade or business whose activities consist of trafficking specified controlled substances, including marijuana. The Personal Income Tax Law conforms to those federal income tax law provisions with respect to deductions.

This bill, for each taxable year beginning on or after January 1, 2020, and before January 1, 2025, would specifically provide in the Personal Income Tax Law for nonconformity to that federal law disallowing a deduction or credit for business expenses of a trade or business whose activities consist of trafficking specified controlled substances only for commercial cannabis activity, as defined under MAUCRSA, by a licensee under MAUCRSA, thus allowing deduction of business expenses paid or incurred during the taxable year in carrying on that commercial cannabis activity under the Personal Income Tax Law.

Section1 of the statute states:

SECTION 1. Section 17209 is added to the Revenue and Taxation Code, to read: 17209.  

  • For each taxable year beginning on or after January 1, 2020, and before January 1, 2025, Section 280E of the Internal Revenue Code, relating to expenditures in connection with the illegal sale of drugs, shall not apply to the carrying on of any trade or business that is commercial cannabis activity by a licensee.


(b) For purposes of this section, “commercial cannabis activity” and “licensee” shall have the same meanings as set forth in Division 10 (commencing with Section 26000) of the Business and Professions Code.

(c) This section shall remain in effect only until December 1,2025, and as of that date is repealed.

 We will have more to say about what this means to businesses that operate as pass-thru entities in California at a point in the future.

The Bill


Video StaffVideo StaffOctober 11, 2019


This is your marijuana money minute for the week ending October 11 from the New West Media in San Francisco. Wow, what a crazy week to see things blow up and more carnage in the cannabis industry. 

Where to start?

MedMen announced it decided to terminate the deal with PharmaCann that had been valued at $684 million. MedMen said it wants to focus more on its California market and go deeper into its strengths. As a consolation prize, Medmen gets PharmaCann’s Illinois licenses as part of the termination fee. Of course, MedMen has been touting its proforma numbers with Pharmacann and so now those have to be dialed back.

Speaking of dialing back, HEXO Corp said that its previously projected revenues were a bit lofty. The company said it had to reduce its revenue estimates to a range of $46-$48 million for the year, significantly lower than the $400 million it said it would do in 2020. That stock got spanked hard.

The Green Organic Dutchman said that it was considering new financing to complete the construction of two of its facilities. The only problem with that is that on previous investment decks, TGOD claimed that their projects were fully funded. The company also says it has $50 million in cash. How much money d they possibly need if they are only weeks away from completion. The stock lost 40% of its value in 2 days. 

More divorce news.

Aleafia said it was no longer going to buy cannabis from Aphria saying Aphria failed to meet its supply obligations. Aphria seemed to toss it off and said they would still achieve net positive income for this past quarter. To make things more awkward, Aphria owns a lot of Aleafia stock.

And then finally, two Russian nationals were arrested for campaign finance violations this week and it turns out that they had applied for marijuana licenses in Nevada. They didn’t get them because they were late by 2 months.

Sean HockingSean HockingOctober 11, 2019


If you wish to re-publish this story please do so with the following accreditation
AUTHOR:  aBIZinaBOX Inc. CPAs – Jordan S. Zoot, CPA

The California Dept. of Tax and Fee Administration [“CDTFA”] just issued a set of regulations that apply to the “Marketplace Facilitator Act”.

This new law which has been unnoticed by most in California’s cannabis industry could be applied to Weedmaps and others who facilitate sales of cannabis to California residents.

A new California law generally provides that a marketplace facilitator is responsible for collecting and paying the tax on retail sales made through their marketplace for delivery to California customers.

A marketplace includes a physical or online place where marketplace sellers sell or offer for sale tangible merchandise for delivery in California.

A marketplace facilitator is generally the operator of the marketplace.

This new law is referred to as the Marketplace Facilitator Act., It was added to California law by Assembly Bill 147 (Stats. 2019, ch. 5) and amended by Senate Bill 92 (Stats. 2019, ch. 34).

CDTFA’s announcement states,

“If you operate a marketplace or sell tangible merchandise through a marketplace, this guide will help you understand the new law and how it affects your sales and use tax registration, collection, and payment responsibilities. Delivery network companies are not marketplace facilitators for purposes of the Marketplace Facilitator Act. However, a delivery network company may elect to be deemed a marketplace facilitator.”


This bill, on and after October 1, 2019, would provide that a marketplace facilitator, as defined, is considered the seller and retailer for each sale facilitated through its marketplace, as defined, for purposes of determining whether that marketplace facilitator is required to register with the department under the Sales and Use Tax Law. The bill would provide that any marketplace facilitator that is registered or required to register with the department under the Sales and Use Tax law and who facilitates a retail sale of tangible personal property by a marketplace seller, as defined, is the retailer selling or making the sale of the tangible personal property sold through its marketplace for purposes of paying any sales taxes and collecting any use taxes.


The bill, for purposes of determining whether a marketplace facilitator has total combined sales of tangible personal property for delivery in this state that would make it a retailer engaged in business in this state, would require the marketplace facilitator to include all sales made on its own behalf and by all related persons and sales facilitated on behalf of marketplace sellers. The bill would provide a marketplace facilitator relief from liability for the tax on a retail sale in specified circumstances.


“Marketplace” means a physical or electronic place, including, but not limited to, a store, booth, internet website, catalog, television or radio broadcast, or a dedicated sales software application, where a marketplace seller sells or offers for sale tangible personal property for delivery in this state regardless of whether the tangible personal property, marketplace seller, or marketplace has a physical presence in this state.


“Marketplace facilitator” means a person who contracts with marketplace sellers to facilitate for consideration, regardless of whether deducted as fees from the transaction, the sale of the marketplace seller’s products through a marketplace operated by the person or a related person and who does both of the following:


  • Directly or indirectly, through one or more related persons, engages in any of the following:

(A) Transmitting or otherwise communicating the offer or acceptance between the buyer and seller.

(B) Owning or operating the infrastructure, electronic or physical, or technology that brings buyers and sellers together.

(C) Providing a virtual currency that buyers are allowed or required to use to purchase products from the seller. 

(D) Software development or research and development activities related to any of the activities described in paragraph (2), if such activities are directly related to a marketplace operated by the person or a related person.


  • Directly or indirectly, through one or more related persons, engages in any of the following activities with respect to the marketplace seller’s products:

(A) Payment processing services.

(B) Fulfillment or storage services.

(C) Listing products for sale.

(D) Setting prices.

(E) Branding sales as those of the marketplace facilitator.

(F) Order taking.

(G) Providing customer service or accepting or assisting with returns or exchanges.


“Marketplace seller” means a person who has an agreement with a marketplace facilitator and makes retail sales of tangible personal property through a marketplace owned, operated, or controlled by a marketplace facilitator, even if that person would not have been required to hold a seller’s permit or permits, or required to collect the tax imposed pursuant to Chapter 3 (commencing with Section 6201), had the sale not been made through that marketplace.



The Marketplace Facilitator Act was enacted to apply to the Wayfair decision by SCOTUS 585 US ____ to sales to California residents. This legislation obviously applies to sales of cannabis to California residents. We wonder whether CDTFA will be clever enough to utilize this new law creatively to rein in the use of the Weedmaps platform and comparable platforms and distributors that facilitate cannabis delivery service operations. Why should CDTFA pursue individual delivery service operators when it can make the distributor or the platform collect the taxes for the agency?   Did we get your attention yet? Which major players should be thinking about the ramifications of California’s new Marketplace Facilitators Act?



More Info From The CDTFA – Click On The Image

Debra BorchardtDebra BorchardtOctober 10, 2019


The two Russian nationals that were arrested on Thursday for campaign finance violations also tried to apply for marijuana licenses in Nevada according to the arrest allegations. The document said that  Lev Parnas, Igor Furman, David Correia and Andrey Kukushkin “planned to use Foreign National-1 as a source of funding for donations and contributions to State and federal candidates and politicians in Nevada, New York and other states to facilitate acquisitions of retail marijuana licenses.”

The group is alleged to have a multi-state license strategy in or about September to October 2018. The group contemplated to use between $1 and $2 million in political contributions. The funding scheduled two $500,000 transfers. “Foreign National-1 then arranged for two $500,000 wires on or about September 18, 2018 and October 16, 2018 to be sent from overseas accounts to U.S. corporate bank account controlled by Frumanand another individual.”

The problem is that the group applied two months too late for a Nevada recreational license even though they attempted to contribute to state politicians. Kukushkin told the group they were “two months too late to the game unless we change the rules.” Then the group discussed needing a particular Nevada state official to push through their application. They gave candidate-1 $10.000, but then it seems the group washed their hands of the license application process.

The document alleges “that they needed a particular Nevada State official, the position for which Candidate-1 was running, to green light to implement this.” As noted above, FRUMAN made a $10,000 donation, funded by
Foreign National-1, to Candidate-1 on or about November 1, 2018. On or about November 4, 20l8, PARNAS asked KUKUSHKIN to arrange for additional funding from Foreign National-l to make an additional donation to Candidate-1, to which KUKUSHKIN responded that the $1 million Foreign National-1 had already provided to GEE was in order to cover all the donations whatsoever.”

Money transferred by [Foreign Nationalel] was to support the very specific people states (per table) in order to obtain green light for licensing. I haven’t changed any rules of our engagement and was present at all the scheduled meetings with officials in Nevada. Although PARNAS, FRUMAN, CORREIA, and Foreign National-l continued to meet into the spring of 2019, the Business Venture did not come to fruition.

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