An Audit and Oversight Report — Up to date February 2026
EXECUTIVE SUMMARY
Writer RN Collins
Contact RN Collins: https://www.linkedin.
Procurement selections made by state hashish regulatory companies—protecting info know-how infrastructure, third-party monitoring distributors, monetary companies contractors, and public-private fund managers—signify among the many highest-stakes, least-scrutinized expenditure classes in state authorities. This report examines procurement oversight in 5 main hashish regulatory companies: the Massachusetts Hashish Management Fee (CCC), New York’s Workplace of Hashish Administration (OCM) and the Dormitory Authority of the State of New York (DASNY), the California Division of Hashish Management (DCC), the Washington State Liquor and Hashish Board (LCB), and the Illinois Hashish Regulation Oversight Workplace (CROO) and related companies.
The findings reveal 4 classes of recurrent procurement dysfunction. First, seed-to-sale monitoring software program contracts have been each the biggest particular person expenditure classes for hashish companies and, in two main states, the websites of failed procurements, insufficient vendor administration, and years-long knowledge voids that compromised regulatory effectiveness. Second, public-private monetary companies contracts—most notably New York’s $200 million Hashish Social Fairness Funding Fund association with DASNY and Chicago Atlantic Group—have allowed non-public contractors to extract vital returns from public packages designed for social fairness, with phrases that company officers themselves warned have been more likely to hurt the borrowing licensees they have been designed to assist. Third, inside monetary controls at hashish companies have in a number of instances failed to satisfy fundamental requirements, producing uncollected revenues, double billing, and undocumented payment waivers. Fourth, vendor consolidation within the seed-to-sale market—now approaching duopoly circumstances following the August 2025 Metrc-BioTrack strategic partnership—poses structural dangers to aggressive procurement in each state that has not locked into long-term contracts.
The Massachusetts CCC audit, revealed August 14, 2025, is essentially the most complete current documentation of inside procurement and monetary management failures at a hashish regulatory physique.¹ The New York DASNY-Chicago Atlantic procurement, documented in investigative reporting by THE CITY and Senate statements, presents a case examine in how public contract constructions can produce non-public achieve on the expense of this system’s meant beneficiaries.² Washington LCB’s decade-long failure to obtain and implement a practical seed-to-sale monitoring system—documented within the 2024 Washington State Auditor follow-up report and additional confirmed by the JLARC Might 2025 Hashish Market Research Preliminary Report—illustrates how insufficient mission administration and management turnover can produce cascading procurement failures that persist for practically twenty years.³ And the rising market construction of seed-to-sale software program, the place two Florida-based companies now collectively serve the overwhelming majority of state hashish markets, raises systemic questions on long-term aggressive procurement viability.⁴
[GAP UPDATE — February 2026]: Because the unique report, a number of materially vital developments have occurred. In California, an Orange County Superior Courtroom decide dominated in December 2025 that the DCC’s Metrc-based monitoring system doesn’t adjust to state regulation requiring it to flag irregularities indicating doable diversion—immediately corroborating issues raised within the Estes whistleblower litigation.⁵ In Massachusetts, the CCC has been working underneath a hiring freeze since Might 2025 because of funds constraints, and its FY 2026 funds request for portal replacements remained unfunded as of early 2026, even because the company reported document adult-use gross sales of $1.65 billion in 2025 and reached a cumulative $8 billion product sales milestone on the finish of June 2025.⁶ New York’s hashish market continued its fast growth—with mixed adult-use and medical gross sales reaching roughly $1.6 billion in 2025—however the state’s CAURD licensees face a brand new disaster involving an OCM location-proximity error affecting 152 dispensaries.⁷ President Trump’s December 18, 2025 Govt Order directing expedited rescheduling of hashish to Schedule III provides an additional fiscal variable: the elimination of IRC Part 280E would materially enhance operator economics, which may in flip strengthen state payment fund solvency—however ultimate rulemaking was not anticipated till someday in 2026 on the earliest.⁸
I. THE PROCUREMENT LANDSCAPE IN CANNABIS REGULATORY AGENCIES
A. Structural Context
State hashish regulatory companies occupy a novel place in state authorities procurement. Their working budgets are sometimes funded by hashish licensing charges, excise tax revenues, and appropriations from cannabis-specific funds somewhat than normal income—a self-financing construction that reduces legislative scrutiny of expenditures whereas making companies closely depending on {industry} development to fund their very own operations. Massachusetts CCC, for instance, acquired whole appropriations of $15,217,877, $19,218,649, and $19,763,742 in fiscal years 2022, 2023, and 2024, respectively—all funded by the Marijuana Regulation Fund somewhat than the overall fund.⁹
These companies additionally function in a website the place the underlying regulated product stays federally prohibited, which creates procurement issues absent from different regulatory contexts. Commonplace authorities contractors—banks, accounting companies, IT distributors—could also be reluctant to supply companies to state hashish companies given federal Schedule I classification. The pool of certified distributors for cannabis-specific capabilities (monitoring software program, compliance programs, cost processing) is subsequently structurally slim, with solely a handful of specialised companies prepared and capable of function within the house.¹⁰ This vendor shortage, mixed with aggressive timelines for standing up new regulatory packages, has repeatedly led states to obtain hashish IT and monetary companies underneath circumstances that compromise aggressive bidding and post-award oversight.
[GAP UPDATE — Rescheduling and Vendor Pool]: President Trump’s December 18, 2025 Govt Order directing the DOJ to reclassify hashish to Schedule III is anticipated, when finalized, to cut back a few of the federal-conflict frictions which have constrained the seller pool. The ultimate rescheduling rule is anticipated within the first half of 2026, although litigation challenges are anticipated.¹¹ Even so, the cannabis-specific IT vendor market—dominated by Metrc and BioTrack—is unlikely to vary considerably within the close to time period. States procuring new programs or renewing contracts in 2026 ought to explicitly plan for a post-280E working atmosphere during which better-capitalized operators can help higher-quality compliance programs.
B. Principal Procurement Classes
The most important procurement classes for state hashish regulatory companies embrace: (1) seed-to-sale monitoring and compliance software program; (2) licensing administration programs and portals; (3) laboratory testing certification and standardization; (4) public-private capital fund administration; and (5) inside audit, authorized, and settlement companies. Every presents distinct procurement oversight challenges, and every has been the location of documented failures in a number of main hashish states.
II. SEED-TO-SALE TRACKING PROCUREMENT: WASHINGTON’S DECADE-LONG FAILURE
A. The LEAF Procurement and Its Collapse
Washington State’s hashish monitoring procurement historical past represents essentially the most extensively documented case of procurement and mission administration failure in any state hashish regulatory company. In 2018, the Washington State Auditor’s efficiency audit discovered the LCB was implementing a monitoring system “subtle sufficient to spotlight danger areas for additional investigations by enforcement officers,” able to robotically flagging suspicious exercise akin to extreme product donations.¹² That system, referred to as LEAF, was procured by vendor MJ Freeway (subsequently rebranded as Akerna) and was meant to switch the present BioTrackTHC platform.
The LEAF procurement failed virtually instantly upon launch. The mission was overseen by three totally different sponsors and three totally different deputy administrators in three years, a governance instability that the 2024 Washington State Auditor follow-up report cited as a principal reason for failure.¹³ MJ Freeway “suffered various mission administration and implementation points,” acknowledged LCB employees in a November 2024 Joint Legislative Audit and Assessment Committee (JLARC) listening to.¹⁴ The system skilled severe glitches that prevented companies from making or reporting gross sales shortly after launch.¹⁵
The Washington State Workplace of the Chief Data Officer (OCIO) issued an in depth lessons-learned report in 2020 documenting a number of failings at each level within the procurement and implementation of LEAF.¹⁶ Among the many mission administration shortcomings recognized have been insufficient necessities definition, poor vendor administration, lack of clear success metrics, inadequate company oversight throughout implementation, and failure to take care of continuity of institutional data by management adjustments.¹⁷ Any one among these points may have compromised a significant software program procurement; taken collectively, they contributed to greater than three years of deficiencies in LCB’s main hashish monitoring software earlier than the company deserted the mission completely.¹⁸
Present LCB management inherited these historic issues following vital management turnover in a number of important roles.¹⁹ The 2024 audit discovered that new leaders weren’t made conscious of the existence of the prior efficiency audit or the OCIO lessons-learned report—a data hole that immediately contributed to the repetition of mission administration errors in subsequent IT planning.²⁰
B. CCRS: A Stopgap That Turned the System
Following the collapse of LEAF, company executives in 2021 determined to cancel the LEAF mission altogether and repurpose an present knowledge backup system for monitoring functions.²¹ This repurposed system—dubbed the Hashish Central Reporting System (CCRS)—was described by company officers as meant to be a brief measure “for maybe only one yr” till a brand new system may very well be procured.²² As a substitute, CCRS stays the first monitoring system for Washington’s hashish {industry} as of 2026.
CCRS’s limitations are extreme and well-documented. Enforcement officers lack real-time monitoring info. The system is susceptible to knowledge entry errors, together with misplaced decimals in reported gross sales costs—errors vital sufficient that CCRS reported annual hashish gross sales of roughly $7.7 billion in 2022, whereas the Division of Income independently estimated the same-period determine at roughly $1.3 billion.²³ Licensed hashish companies can not view their very own knowledge within the system after add and should submit a public information request to confirm the accuracy of their very own submissions.²⁴ Merchandise wouldn’t have single identification numbers, complicating product recall monitoring.²⁵ CCRS has no API, that means third-party software program suppliers can not entry the system programmatically.²⁶
LCB doesn’t count on to completely implement a extra strong monitoring system till 2031—practically twenty years after Washington voters legalized leisure hashish.²⁷ The JLARC Might 2025 Hashish Market Research Preliminary Report discovered that 88 % of adult-use states use one among two business seed-to-sale traceability programs, making Washington a notable outlier that can’t produce the info high quality its regulatory obligations require.²⁸
[GAP UPDATE — LCB Traceability Planning, 2025–2026]: The JLARC Might 2025 preliminary report included a selected advice that the LCB submit a plan to legislative committees by December 31, 2025, figuring out assets and funding wanted to gather correct knowledge from licensees by December 31, 2026. The LCB’s traceability modernization is structured throughout three phases: provide chain monitoring for 2025–2026; tracing distribution to retail channels for 2027–2028; and full gross sales and income tracing from 2029–2031.²⁹ In parallel, Governor Inslee’s workplace declined to incorporate new traceability system funding within the proposed FY 2026 funds, prompting Hashish Observer to notice that the “lump of coal” from the Governor might “lastly fireplace up CCRS API growth.”³⁰ As of early 2026, LCB had recruited a devoted Traceability Mission Supervisor however had not but issued a aggressive procurement solicitation for a substitute system. The company’s capability to realize the JLARC’s December 2026 data-quality milestone absent a funded procurement stays unsure.
C. Procurement Classes from Washington
The Washington LCB expertise yields a number of procurement classes relevant throughout state hashish regulatory contexts. Vendor due diligence should assess not solely technical functionality but additionally post-award implementation capability; MJ Freeway’s capability to contract for LEAF didn’t predict its capability to ship it. Contract governance constructions—together with oversight continuity, escalation pathways, and efficiency milestones—should be laid out in procurement paperwork and enforced post-award. Management turnover throughout the procuring company should not be allowed to create data voids about ongoing contracts, and institutional reminiscence about classes discovered from prior procurements should be systematically preserved and transmitted to incoming executives.³¹
III. SEED-TO-SALE MARKET CONSOLIDATION: THE METRC-BIOTRACK DUOPOLY
A. Market Construction and Contract Focus
The seed-to-sale monitoring software program marketplace for state hashish regulatory packages has consolidated into near-duopoly circumstances dominated by two Florida-based companies: Metrc, headquartered in Lakeland, and BioTrack, headquartered in Fort Lauderdale.³² As of August 2025, Metrc held contracts with 29 states requiring licensed hashish operators to make use of its RFID-tag-based monitoring software program.³³ BioTrack held contracts with roughly eight states.³⁴
On August 5, 2025, Metrc and BioTrack introduced a “strategic partnership” underneath which a brand new entity—BT Authorities—would take over BioTrack’s government-facing operations and function independently from each Metrc and BioTrack.³⁵ The phrases of the deal weren’t publicly disclosed.³⁶ Following the announcement, Metrc is positioned to function monitoring programs within the overwhelming majority of authorized hashish states. The partnership left state hashish regulators and licensed operators unsure in regards to the implications for present contracts and future aggressive procurement.³⁷
New York, beforehand underneath contract with BioTrack and within the means of transitioning its BioTrack-based seed-to-sale system, was significantly disrupted. The OCM briefly halted track-and-trace compliance necessities following the partnership announcement and finally delayed implementation from its deliberate rollout date till a minimum of 2026.³⁸ New York’s take care of BioTrack, signed in late 2022, was price roughly $1.2 million over 5 years—a fraction of the $113 million California agreed to pay Metrc for a four-year contract starting July 1, 2024.³⁹ The intense disparity in contract values displays each the dimensions variations between the 2 markets and the distinction in leverage accessible to a state procuring a brand new system versus one extending a longtime vendor relationship.
B. Illinois: Aggressive Procurement and Vendor Transition
Illinois affords a contrasting mannequin of aggressive procurement that yielded a vendor transition away from BioTrack to Metrc. After a aggressive procurement course of, the Illinois Hashish Regulation Oversight Workplace issued a Discover of Award to Metrc to supply the state’s seed-to-sale monitoring resolution.⁴⁰ The proposed resolution contemplates transitioning from incumbent BioTrack to Metrc over a 180-day interval following contract execution.⁴¹ Illinois’ system is designed to take care of and improve core IT and enterprise functionalities whereas including a regulatory portal for state customers, a enterprise portal for licensees, and a client portal for public entry.⁴² The Illinois expertise means that aggressive procurement is achievable even in a consolidated market, although the end result—a transfer to the market-dominant vendor—itself displays the constraints imposed by a duopolistic market construction.
C. The Metrc Whistleblower Litigation and the California Courtroom Ruling
A federal whistleblower lawsuit filed on April 4, 2025 within the U.S. District Courtroom for the District of Oregon by former Metrc govt vice chairman Marcus Estes raised vital questions in regards to the adequacy of Metrc’s efficiency of its state contracts.⁴³ Estes alleged that Metrc possessed the technical functionality to robotically determine and flag irregularities in its monitoring knowledge—together with what he characterised as widespread “burner distro” operations facilitating unlawful interstate hashish diversion in California—however was selecting to not train that functionality with a view to shield its profitable RFID income streams and preserve favorable contractual standing with state shoppers.⁴⁴
Estes claimed that regardless of Metrc’s roughly $40 million-per-year contract with California containing a requirement to “flag irregularities,” the corporate’s executives dismissed his inside issues, telling him that flagging irregularities was “not our job.”⁴⁵ Metrc disputed the characterizations and described Estes as a terminated worker engaged in retaliation after being dismissed for efficiency points.⁴⁶ The Oregon case was dismissed with out prejudice on June 9, 2025 by Decide Karin J. Immergut on the bottom that the claims overlapped with associated litigation Metrc had filed in opposition to Estes in U.S. District Courtroom for the Center District of Florida; that Florida litigation remained pending as of early 2026.⁴⁷
[GAP UPDATE — California Court Ruling, December 2025]: In December 2025, an Orange County Superior Courtroom decide independently dominated that the DCC’s present Metrc-based monitoring system doesn’t adjust to California state regulation, which requires the track-and-trace system to flag irregularities that sign doable diversion of authorized product to the illicit market.⁴⁸ The lawsuit was introduced by a big California hashish retailer alleging that the DCC had didn’t adequately implement the flagging necessities. The ruling—echoing the core allegation in Estes’ whistleblower grievance—means that contractual vendor obligations to determine diversion indicators aren’t self-executing and require energetic state oversight. The DCC had not but introduced adjustments to its Metrc implementation as of early 2026, although the ruling is anticipated to immediate contractual and regulatory changes.⁴⁹ The allegations, if additional substantiated by ongoing litigation, would signify a class of procurement efficiency failure—a vendor declining to carry out core contractual obligations with out detection or consequence—with implications for each state counting on Metrc’s platform.
D. RFID Tag Value-Shifting
A structural function of Metrc’s and BioTrack’s authorities contract fashions that procurement oversight has inadequately addressed is the cost-shifting of RFID tag purchases to licensed operators. Beneath most state Metrc contracts, the state pays a software-as-a-service payment to the seller, however licensed operators are moreover required to buy RFID tags from the seller to affix to crops and merchandise.⁵⁰ This creates a twin income stream for the seller—authorities contract funds and necessary tag gross sales to regulated companies—that successfully compels operators to subsidize the seller’s revenue past the contracted authorities payment.
New York operators have been significantly vocal about BioTrack’s tag pricing necessities through the state’s tried transition, noting {that a} proposed requirement to affix 10-cent figuring out tags to just about each particular person product—together with particular person pre-rolls—would impose prices at a scale inconsistent with the economics of authorized hashish retail.⁵¹ Critics additionally identified that the “sublot” requirement underlying the per-unit tagging mandate was not laid out in New York state regulation.⁵² The OCM finally coated as much as $250,000 in preliminary stock tag purchases as an operator help measure when the BioTrack system first launched in November 2024.⁵³
[GAP UPDATE — New York Metrc Litigation, December 2025]: A lawsuit filed in December 2025 within the Supreme Courtroom of the State of New York challenges the OCM’s implementation of Metrc with out public remark or legislative authorization, arguing that the necessary unique-identifier-per-product requirement (somewhat than per-batch monitoring) will dramatically enhance prices for small operators and work in opposition to the MRTA’s targets of decreasing the illicit market.⁵⁴ The litigation highlights the persistent stress between operational monitoring granularity and financial burden on small, equity-focused licensees that has characterised New York’s repeated monitoring system delays.
IV. MASSACHUSETTS CCC: INTERNAL FINANCIAL CONTROLS AND FEE COLLECTION FAILURES
A. The August 2025 State Auditor Report
The Massachusetts State Auditor’s Workplace, underneath Auditor Diana DiZoglio, revealed a complete sixty-page audit of the Hashish Management Fee (CCC) on August 14, 2025, protecting the interval from July 1, 2022 by June 30, 2024.⁵⁵ The audit documented seven main findings, all of which relate on to inside monetary controls, payment assortment, income classification, and contract administration.
The CCC regulates what has change into an roughly $8 billion hashish {industry} in Massachusetts—a cumulative product sales milestone crossed on the finish of June 2025, with the fee additionally reporting $1.65 billion in adult-use gross sales in calendar yr 2025, a brand new annual document.⁵⁶ It acquired whole appropriations of roughly $19.8 million in fiscal yr 2024, funded by the Marijuana Regulation Fund.⁵⁷ The audit interval coincided with a interval of maximum institutional dysfunction on the company: former CCC Chairwoman Shannon O’Brien was employed in September 2022, suspended in September 2023, and fired in September 2024 amid accusations of racially, ethnically, and culturally insensitive statements, in addition to contributing to a hostile work atmosphere.⁵⁸ Unsealed court docket paperwork confirmed widespread mistrust and interpersonal battle amongst senior company staff throughout this era.⁵⁹
B. The Prorated Price Disaster
The audit’s first and most extensively coated discovering concerned the CCC’s failure to persistently gather prorated license extension charges. On August 11, 2022, CCC commissioners voted to delegate authority to the manager director to administratively lengthen license expiration dates by as much as 120 days, with licensees required to pay a prorated payment to cowl the extension interval.⁶⁰ CCC licensing employees didn’t implement this directive. For nearly two years—from August 2022 by a minimum of June 2024—the licensing director continued granting extensions with out accumulating charges, regardless of the fee’s specific authorization.⁶¹
The CCC’s personal Workplace of the Inspector Basic (OIG) investigation, initiated in July 2024 following a hotline grievance, discovered greater than $550,000 in foregone income from 159 license extension requests for which prorated charges weren’t collected.⁶² Inspector Basic Jeffrey S. Shapiro described the failure as “an egregious operational breakdown” and famous that the “incapacity of CCC employees to implement a key fee initiative ought to have been readily obvious to supervisors and commissioners in actual time.”⁶³
Moreover, the OIG discovered that for nearly two years the CCC didn’t gather as much as $1.2 million in potential charges from greater than 120 provisional license candidates who have been permitted to carry provisional license approvals past the 90-day cost deadline with out penalties.⁶⁴ As of March 2025, the CCC had collected roughly $320,681 of the initially recognized $550,000 in prorated charges, with roughly $170,000 remaining uncollected.⁶⁵ The CCC agreed to retain impartial audit agency Clifton Larson Allen to finish a complete payment overview, with that engagement anticipated to conclude in July-August 2025.⁶⁶
The audit’s investigation additionally discovered that the prorated payment assortment failures weren’t uniformly distributed—some hashish companies have been required to pay extension charges whereas others inexplicably weren’t, with no information saved of when or why charges have been waived.⁶⁷ Auditor DiZoglio’s workplace characterised this as creating “the looks of potential favoritism and/or impropriety” that “may erode the general public’s belief in CCC.”⁶⁸ In Brookline, for instance, the audit discovered that one hashish enterprise was required underneath its host group settlement (HCA) to make a $975,000 charitable donation, whereas a second enterprise working in the identical municipality confronted no such requirement.⁶⁹
C. Monetary Reporting and Income Classification Failures
Past the payment assortment deficiencies, the audit discovered the CCC didn’t determine double funds for license charges and didn’t be certain that revenues have been correctly coded and categorized.⁷⁰ These failures produced monetary misstatements and reporting inaccuracies, elevated noncompliance danger, and “potential for monetary loss or fraud” in line with the auditor.⁷¹ The company didn’t preserve information of situations when charges have been waived, making it inconceivable to retrospectively reconcile whole foregone income.⁷²
D. Host Group Settlement Oversight Failures
Chapter 180 of the Acts of 2022 gave the CCC oversight accountability over Host Group Agreements (HCAs)—contracts between hashish companies and the municipalities during which they function, which can specify hours of operation, safety plans, group affect charges (CIFs), and charitable contributions.⁷³ The CCC’s HCA oversight authority turned efficient November 10, 2022.⁷⁴ Nevertheless, the CCC didn’t start reviewing HCAs till March 1, 2024—greater than fifteen months after its oversight authority was established.⁷⁵ Noncompliant HCAs containing unenforceable language and impermissible provisions remained in impact for between 4 and sixteen months longer than permitted underneath state regulation.⁷⁶
The CCC opted to start reviewing Group Influence Price (CIF) documentation inside HCAs a minimum of six months after beginning the HCA overview course of—not till November 2024.⁷⁷ State regulation caps CIFs at three % of product sales; the audit discovered HCAs requiring mandated charitable donations or municipal contributions above the statutory cap weren’t recognized and remediated in a well timed method.⁷⁸
E. Settlement Settlement Documentation Deficiencies
The audit recognized an absence of documented course of for a minimum of three worker settlement agreements entered into between 2019 and 2024, one among which was for practically $93,000.⁷⁹ As an company of the Commonwealth, the CCC is topic to Chapter 258 of the Basic Legal guidelines and the Comptroller’s “Settlements and Judgments Coverage” requiring documentation of settlement processes and approvals.⁸⁰ The absence of documentation for these agreements—involving allegations associated to defamation, invasion of privateness, and household medical depart rights—raises issues in regards to the adequacy of authorization and overview for public expenditures on worker litigation.⁸¹
F. Expertise Procurement and Infrastructure Wants — Up to date Standing
The CCC’s present know-how infrastructure was recognized within the audit as insufficient for an company regulating an {industry} that has now reached $8 billion in cumulative product sales. The fee sought funds in each its fiscal yr 2025 and monetary yr 2026 state funds requests to replace or substitute its adult-use licensing portal (MassCIP) and its medical marijuana platform (MMJOS), however neither request was granted.⁸²
[GAP UPDATE — Hiring Freeze and Procurement Status, 2025–2026]: The CCC confirmed in response to the audit that it has been working underneath a hiring freeze since Might 2025 by the start of FY 2026 because of a discount in its working funds. The company said it’s “not capable of obtain satisfactory staffing or spend money on automation as a result of ongoing funds restraints,” whereas concurrently continuing with a public procurement course of for IT infrastructure upgrades and exploring potential funding by the Govt Workplace of Expertise Providers and Safety (EOTSS).⁸³ The fee’s FY 2026 funds request of $30.08 million—which might have funded 21 new positions, expanded product testing, up to date platforms, and social fairness programming—was not funded at that stage, deepening the company’s operational squeeze.⁸⁴ Commonplace Working Procedures for prorated payment assortment have been created in April 2025, and the CCC accomplished preparation for a System and Group Management (SOC) 2 audit utilizing end-of-FY 2025 accessible funding.⁸⁵ Moreover, in December 2025, the CCC unanimously accepted ultimate laws for on-site hashish consumption, creating three new social consumption license varieties—Supplemental, Hospitality, and Occasion Organizer—with laws taking impact January 2, 2026.⁸⁶ This growth of the regulatory mandate additional will increase the operational and know-how calls for on an company already constrained by funds shortfalls and insufficient IT infrastructure.
V. NEW YORK: THE DASNY-CHICAGO ATLANTIC PROCUREMENT CONTROVERSY
A. The $200 Million Hashish Social Fairness Funding Fund
New York’s most consequential hashish procurement was not a software program contract however a public-private financing association: the New York Hashish Social Fairness Funding Fund, licensed by statute and administered by DASNY, designed to finance the development and lease of retail dispensary storefronts for CAURD licensees.⁸⁷ Reuben McDaniel, then-head of DASNY, proposed and designed the fund, projecting a $200 million car with non-public fairness participation to finance the primary 150 dispensaries.⁸⁸
DASNY chosen Chicago Atlantic Group—a Chicago-based non-public fairness agency—because the fund’s non-public capital accomplice, committing $50 million in non-public financing.⁸⁹ As of Might 1, 2024, roughly $27 million had been funded.⁹⁰ The state was answerable for repaying Chicago Atlantic at a 15 % rate of interest whilst CAURD licensing approvals stalled and the fund didn’t deploy capital at its deliberate tempo.⁹¹
B. Phrases That State Officers Warned Had been Predatory
Investigative reporting by THE CITY, revealed April 24, 2024, primarily based on confidential paperwork obtained from the fund, revealed the particular phrases of the Chicago Atlantic deal and documented inside company objections that have been apparently disregarded.⁹² In keeping with THE CITY’s reporting, OCM’s personal authorized counsel warned internally a couple of excessive chance of defaults that the state could be on the hook for.⁹³ Inner emails confirmed state officers elevating flags about inflated development prices and mortgage phrases that made compensation unrealistic given projected income.⁹⁴
In a single documented case, a dispensary build-out with development and design prices of roughly $1.7 million resulted in a complete mortgage obligation of roughly $2.1 million after extra charges and bills—roughly double the excessive finish of the vary that DASNY and the fund had beforehand communicated to licensees.⁹⁵ CAURD licensees weren’t knowledgeable of the ultimate lending price earlier than being anticipated to simply accept a DASNY-selected location or be part of this system.⁹⁶ Building work was carried out by ten companies pre-selected by DASNY’s request-for-proposal course of, eradicating operators’ capability to barter prices or choose contractors.⁹⁷
State Senators Liz Krueger and Gustavo Rivera issued an announcement characterizing the fund phrases as “clearly predatory mortgage agreements,” noting that CAURD licensees confronted “an inconceivable alternative: enter the market with out monetary help, or signal a deal that supplied zero management of design, buildout, or auxiliary prices with mortgage quantities that ballooned past practical income projections.”⁹⁸ Reinvent Albany senior coverage advisor Rachael Fauss noticed that “the state is taking over the entire danger,” with the non-public entity—Chicago Atlantic—capturing the advantages.⁹⁹
C. Outcomes: 21 Dispensaries for $78 Million — and Persevering with Fallout
Towards a objective of 150 dispensaries, the SEIF finally delivered 21 operational dispensaries at a reported value of roughly $78 million.¹⁰⁰ DASNY signed leases for less than 24 properties by the tip of December 2024 and subsequently stopped looking for new leases by the fund.¹⁰¹ In Might 2024, DASNY introduced a restructuring underneath which Chicago Atlantic would as an alternative buy properties for future dispensaries, gather lease from operators, and permit licensees to pursue their very own build-outs.¹⁰² New York State Senate Finance Committee Chair Liz Krueger, studying of this structural change throughout a affirmation listening to for incoming DASNY CEO Robert Rodriguez, said that the change was “a brand new idea” she had “by no means heard of.”¹⁰³
The fund’s failure contributed to the termination of OCM’s govt management. OCM Govt Director Chris Alexander didn’t return when his time period expired in September 2024.¹⁰⁴ Appearing Govt Director Felicia Reid was pushed out in December 2025 following a separate regulatory administration failure involving the OCM’s enforcement case in opposition to Omnium, which resulted in a failed product recall and withdrawn disciplinary motion.¹⁰⁵
[GAP UPDATE — CAURD Dispensary Location Crisis, 2025–2026]: A brand new disaster emerged in late 2025 and early 2026 when the OCM notified 152 CAURD dispensaries that an error in how the company measured college proximity setbacks—switching from front-door to property-line measurements—probably threatened their license validity. Governor Hochul publicly characterised the episode as “a significant screw up” and pledged that present dispensaries wouldn’t be punished for the failures of previous OCM management.¹⁰⁶ A minimum of one dispensary proprietor with a DASNY fund mortgage particularly cited the proximity notification as threatening his capability to repay that mortgage obligation.¹⁰⁷ Laws was launched requiring the OCM to behave on proximity purposes inside 30 days (with automated approval absent motion if setback necessities are met) and requiring DASNY to publish and weekly replace an inventory of executed lease addresses for CAURD licensees.¹⁰⁸ These developments additional illustrate how procurement failures—on this case, the SEIF’s monetary construction—compound with regulatory administration failures to threaten the viability of social fairness licensees.
D. Seed-to-Sale: New York’s Repeated Delays
New York launched authorized adult-use hashish gross sales in December 2022 and not using a practical seed-to-sale monitoring system—a procurement failure that contributed to ongoing product inversion and diversion issues within the state’s market.¹⁰⁹ The state subsequently contracted with BioTrack and required licensees to acquire third-party stock monitoring programs able to integrating with BioTrack’s API by January 17, 2025.¹¹⁰ The OCM coated as much as $250,000 in stock tag purchases to ease the transition.¹¹¹
Following the August 5, 2025 Metrc-BioTrack strategic partnership announcement—which raised uncertainty in regards to the continuity and governance of BioTrack’s authorities operations—the OCM delayed the BioTrack system’s necessary adoption and finally shifted to Metrc as its track-and-trace vendor.¹¹² Retail licensees have been required to be credentialed in Metrc by December 17, 2025, with present stock entered by January 12, 2026.¹¹³ This represents a minimum of the third time New York regulators delayed seed-to-sale monitoring.¹¹⁴
VI. CALIFORNIA: THE $100 MILLION GRANT PROCUREMENT OVERSIGHT FAILURE
A. Staffing and Administrative Failures
California State Auditor Grant Parks documented in Report No. 2023-048, revealed August 2024, that the DCC administered its $100 million Native Jurisdiction Help Grant Program with solely two individuals tasked with part-time grant administration obligations on the time of preliminary administration.¹¹⁵ This understaffing was a root reason for the audit’s discovering that “DCC accepted questionable spending plans and superior grant funds to recipients who weren’t ready to obtain them” and that “DCC had not scrutinized grantee expenditures and didn’t monitor grantees’ progress towards outlined targets.”¹¹⁶
After the State Auditor communicated issues to DCC through the audit course of, the company employed 4 extra employees members, bringing the overall to 6 individuals engaged on the Grant Program.¹¹⁷ The follow-up report (2024-048, revealed February 2025) discovered continued issues in grant closeout and monetary accountability, with $4,094,936.57 in unspent and ineligible expenditures returned from six of seventeen grant agreements as of August 2025.¹¹⁸
The follow-up audit revealed November 2025 (Report No. 2025-048) directed the DCC to implement a transparency course of for publicly reporting on its web site the ultimate quantities disbursed, used, recaptured, and returned for every native jurisdiction—a fundamental accountability measure absent from this system’s unique design.¹¹⁹
B. The Humboldt County Subgrant Challenge
The California audits recognized a selected grant procurement compliance problem involving Humboldt County’s use of LJAG funds for subgrants to hashish companies that had already obtained annual state licenses—a use the State Auditor concluded didn’t align with the legislative intent of this system.¹²⁰ The DCC accepted Humboldt County’s subgrant method, figuring out that it “furthered the intent of the Grant Program.”¹²¹ The State Auditor disagreed, noting that offering subgrants to companies that had already obtained annual state licenses fell exterior the scope for which the Legislature appropriated LJAG funds.¹²²
C. The Metrc Contract and the December 2025 Courtroom Ruling
California’s four-year Metrc contract, starting July 1, 2024, is price $113.6 million, at an annual contract worth to not exceed $28.4 million.¹²³ With an choice for a two-year extension, the complete potential contract worth is roughly $170 million.¹²⁴ That is the biggest hashish monitoring software program contract within the nation and represents the only largest vendor contract for any state hashish regulatory physique.
[GAP UPDATE — Court Ruling on DCC’s Track-and-Trace Obligations]: In December 2025, an Orange County Superior Courtroom decide dominated that the DCC’s present Metrc-based monitoring system doesn’t adjust to state regulation requiring the system to flag irregularities signaling doable diversion of authorized product to the illicit market.¹²⁵ The lawsuit was introduced by a big California hashish retailer. As of early 2026, the DCC had not but introduced modifications to its Metrc contract or implementation to deal with the court docket’s findings.¹²⁶ The ruling—mixed with the Estes whistleblower litigation’s allegations that Metrc executives explicitly declined to flag irregularities as “not our job”—presents a convergent image of vendor non-performance in a core regulatory perform that California taxpayers are paying as much as $28.4 million per yr to obtain. Moreover, the DCC’s FY 2025-26 funds (roughly $169 million) faces a structural deficit: Governor Newsom proposed shifting enforcement funding from the Hashish Management Fund to the Hashish Tax Fund—a transfer designed to alleviate the fund steadiness stress attributable to the fund’s declining trajectory ($154.3 million in FY 2023-24 to a projected $82.4 million in FY 2025-26)—whereas concurrently authorizing the DCC to close down unlawful operations and gather background info on properties used for illicit cultivation.¹²⁷
VII. CROSS-CUTTING FINDINGS AND RECOMMENDATIONS
A. The Slim Vendor Pool Downside
Each main procurement dysfunction recognized on this report was materially worsened by the slim pool of certified cannabis-specific distributors. Washington LCB’s incapacity to rapidly substitute LEAF was partly attributable to the restricted provide of hashish monitoring platforms prepared to work within the regulated house. New York’s repeated seed-to-sale delays have been compounded by disruptions in a market dominated by two distributors, one among which was within the means of restructuring its government-facing operations. Massachusetts CCC’s know-how improve wants go unaddressed partially as a result of the procurement course of for specialised hashish regulatory know-how is advanced and sluggish.
Addressing vendor pool limitations requires states to coordinate procurement planning throughout companies, share contract phrases, and discover whether or not federal frameworks—akin to a nationwide hashish regulatory know-how clearinghouse, which might require Congressional motion—may enhance market competitors. The December 18, 2025 Govt Order directing hashish rescheduling to Schedule III, if finalized, might modestly broaden the pool of know-how distributors prepared to have interaction the hashish regulatory sector by decreasing federal-conflict dangers.¹²⁸
B. Governance Continuity and Institutional Reminiscence
Washington LCB’s procurement failures have been demonstrably worsened by management turnover that created data gaps about prior audits and lessons-learned stories.¹²⁹ Massachusetts CCC’s payment assortment failures persevered for 2 years partly as a result of supervisors have been described as “agnostic” to the difficulty and centered on different priorities.¹³⁰ Each failures replicate organizational cultures during which procurement and monetary management obligations have been insufficiently institutionalized relative to operational calls for. Hashish regulatory companies needs to be required to take care of complete contract administration registries and to supply structured briefings on energetic procurements and prior procurement failures to all incoming senior executives.
C. Public-Non-public Contract Transparency
The New York DASNY-Chicago Atlantic association illustrates the danger of public-private hashish contracts that prioritize pace of deployment over clear phrases. The monetary phrases of the Chicago Atlantic deal—together with the 15 % rate of interest and the construction whereby Chicago Atlantic would obtain the complete return on licensees’ borrowing prices, regardless of holding solely a 75 % portfolio stake—weren’t disclosed publicly when the association was introduced.¹³¹ State procurement legal guidelines governing DASNY monetary engagements didn’t seem to require public disclosure of those phrases, and the Legislature discovered of a significant structural change to this system solely accidentally throughout a affirmation listening to.¹³² Hashish public-private fund contracts ought to require full disclosure of all monetary phrases, price constructions, and efficiency expectations as a situation of contract execution.
D. Price Assortment and Income Reconciliation Controls
The Massachusetts CCC audit’s discovering that over $550,000 in prorated charges went uncollected for 2 years with out detection displays a failure of fundamental income reconciliation controls. Each hashish regulatory company ought to preserve a complete payment registry monitoring all licenses, relevant payment quantities, collected quantities, and licensed waivers—with reconciliation in opposition to licensee information carried out at minimal on a quarterly foundation. Waivers ought to require documented authorization on the supervisory stage and needs to be reported to commissioners or equal governing our bodies.
E. Suggestions
- Obligatory Procurement Documentation. State hashish regulatory companies ought to preserve a publicly accessible contract registry itemizing all energetic contracts, contract values, vendor names, efficiency metrics, and audit rights. Procurements above an outlined threshold (e.g., $1 million) ought to require impartial overview by the state auditor previous to execution.
- Seed-to-Sale Market Competitors Coverage. States ought to undertake multi-vendor hashish monitoring frameworks the place possible, or at minimal require aggressive solicitation at each contract renewal somewhat than sole-source renewals. Contract phrases ought to require distributors to supply state companies with direct entry to all regulatory knowledge impartial of the seller’s platform—eliminating data-hostage dynamics that enhance vendor leverage at renewal. Contract phrases ought to particularly require distributors to actively flag irregularities indicative of diversion, with enforceable efficiency requirements and third-party audit rights, in gentle of each the Estes whistleblower litigation and the December 2025 California court docket ruling discovering Metrc’s present implementation noncompliant with state diversion-flagging necessities.
- Whistleblower Response Protocols. State hashish regulatory companies that obtain whistleblower complaints relating to vendor efficiency of compliance monitoring obligations needs to be required to research inside an outlined timeframe and to report findings to the legislature.
- Public-Non-public Fund Governance. Any public fund managed by a personal fairness accomplice utilizing state authorization needs to be topic to full monetary disclosure necessities, together with all rates of interest, payment constructions, return allocation mechanisms, and efficiency targets. Legislative committees ought to obtain annual impartial stories on fund efficiency. No main structural adjustments to fund operations needs to be permitted with out prior legislative discover.
- Expertise Finances Safety. Hashish regulatory companies ought to set up devoted know-how reserve funds inside their funds constructions to make sure that IT upgrades and replacements can proceed on a scheduled foundation with out dependence on unpredictable annual appropriations. The Massachusetts CCC’s incapacity to improve its portals because of unmet funds requests—regardless of regulating an {industry} producing $1.65 billion in annual adult-use gross sales and having reached $8 billion in cumulative gross sales—represents a structural vulnerability that periodic emergency appropriations can not adequately tackle.
ENDNOTES
¹ Mass. State Auditor’s Workplace, Audit of the Hashish Management Fee (Audit No. 2025-1477-3S, Aug. 14, 2025), https://www.mass.gov/doc/audit-report-cannabis-control-commission/obtain.
² Rosalind Adams, How Non-public Fairness Trumped Social Fairness in State Hashish Deal, THE CITY (Apr. 24, 2024), https://www.thecity.nyc/2024/04/24/cannabis-fund-social-equity-dispensary/.
³ Wash. State Auditor’s Workplace, Evaluating Oversight of the Hashish Business: Comply with-Up Points (Oct. 2024), https://sao.wa.gov/reports-data/audit-reports/evaluating-oversight-cannabis-industry-follow-issues; JLARC, Hashish Market Research Preliminary Report (Might 2025), https://leg.wa.gov/JLARC/stories/2025/CannabisMarket/p_a/print.pdf.
⁴ ‘Partnership’ or Consolidation? Hashish Software program Deal Leaves Business Guessing, MJBizDaily (Aug. 7, 2025), https://mjbizdaily.com/information/consolidation-or-partnership-cannabis-software-deal-leaves-industry-guessing/406235/.
⁵ California Hashish Regulation Information, Orange County Decide Guidelines DCC Observe-and-Hint System Non-Compliant (Jan. 2026), https://hashish.lacity.gov/articles/january-2026-news-bulletin.
⁶ Mass. Hashish Management Fee, Massachusetts Grownup-Use Hashish Gross sales Generated $1.65 Billion Complete in 2025 (Jan. 9, 2026), https://masscannabiscontrol.com/2026/01/massachusetts-adult-use-cannabis-sales-generated-1-65-billion-in-2025/; Mass. State Auditor’s Workplace, Hashish Management Fee—Discovering 1 (company response noting hiring freeze efficient Might 2025), https://www.mass.gov/info-details/cannabis-control-commission-finding-1.
⁷ N.Y. OCM, 2025 Annual Report (Dec. 31, 2025), https://hashish.ny.gov/system/recordsdata/paperwork/2025/12/cannabis-control-board-and-office-of-cannabis-management-release-2025-annual-report.pdf; News10, Governor Says Hashish Dispensaries Will Not Face Closures (Aug. 2025), https://www.news10.com/information/ny-news/ocm-enforcement-change-threatens-cannabis-dispensaries/amp/.
⁸ Govt Order, Growing Medical Marijuana and Cannabidiol Analysis (Dec. 18, 2025), summarized at Goodwin LLP, Bye-Bye 280E (Dec. 23, 2025), https://www.goodwinlaw.com/en/insights/publications/2025/12/alerts-practices-can-bye-bye-280e.
⁹ Mass. State Auditor’s Workplace, Overview of Audited Entity, https://www.mass.gov/info-details/audit-of-the-cannabis-control-commission-overview-of-audited-entity-0.
¹⁰ Clark Hill PLC, The Rising Cybersecurity Dangers within the Hashish Business (2025), https://www.clarkhill.com/news-events/information/the-growing-cybersecurity-risks-in-the-cannabis-industry/.
¹¹ AAFCPAs, Govt Order to Reschedule Hashish: What It Means for IRC 280E (Dec. 19, 2025), https://www.aafcpa.com/2025/12/19/executive-order-to-reschedule-cannabis-what-it-means-for-irc-280e/.
¹² Wash. State Auditor’s Workplace, State’s Hashish Monitoring System Falls In need of Lengthy-Sought Targets, Audit Finds (Oct. 22, 2024), https://sao.wa.gov/the-audit-connection-blog/states-cannabis-tracking-system-falls-short-long-sought-goals-audit-finds.
¹³ Wash. State Auditor’s Workplace, Evaluating Oversight of the Hashish Business: Comply with-Up Points, supra notice 3.
¹⁴ JLARC I-900 Subcommittee, Public Listening to on Oversight of the Hashish Business (Nov. 6, 2024), Hashish Observer abstract, https://hashish.observer/observations/92200-jlarc-i-900-subcommittee-public-hearing-november-6-2024-oversight-of-the-cannabis-industry/.
¹⁵ Washington’s Marijuana Monitoring System Is Unreliable, Auditors Report Says, Marijuana Second (Oct. 26, 2024), https://www.marijuanamoment.web/washingtons-marijuana-tracking-system-is-unreliable-auditors-report-says/.
¹⁶ Wash. Workplace of the Chief Data Officer (OCIO), Leaf Information Techniques Classes Discovered Report (2020), cited in Wash. State Auditor’s Workplace, supra notice 3.
¹⁷ Id.
¹⁸ Id.
¹⁹ Wash. State Auditor’s Workplace, Evaluating Oversight, supra notice 3.
²⁰ Id.
²¹ Washington’s Marijuana Monitoring System Is Unreliable, supra notice 15.
²² Id.
²³ Wash. State Auditor’s Workplace, State’s Hashish Monitoring System Falls Quick, supra notice 12.
²⁴ Wash. State Liquor and Hashish Board, CCRS FAQ, https://lcb.wa.gov/ccrs/faq.
²⁵ Wash. State Auditor’s Workplace, State’s Hashish Monitoring System Falls Quick, supra notice 12.
²⁶ Wash. LCB, CCRS FAQ, supra notice 24 (“There is no such thing as a Utility Programming Interface (API) for CCRS.”).
²⁷ Wash. State Auditor’s Workplace, Evaluating Oversight, supra notice 3.
²⁸ JLARC, Hashish Market Research Preliminary Report (Might 2025), supra notice 3, at 3–4.
²⁹ WSLCB Communications, CCRS and the Way forward for Hashish Traceability (Medium, Jan. 18, 2024), https://medium.com/wslcb-topics-and-trends/ccrs-and-the-future-of-cannabis-traceability-00b76b03235a (describing phased traceability modernization roadmap); JLARC Hashish Market Research Preliminary Report, supra notice 3 (recommending LCB submit knowledge useful resource plan by December 31, 2025).
³⁰ Hashish Observer, WA Legislature (February 2, 2026) Replace, https://hashish.observer/organizations/1134-washington-state-liquor-and-cannabis-board/ (noting Governor’s funds omission might immediate CCRS API growth).
³¹ Wash. State Auditor’s Workplace, Evaluating Oversight, supra notice 3.
³² ‘Partnership’ or Consolidation?, supra notice 4.
³³ Metrc & BioTrack, Strategic Partnership Press Launch (Aug. 5, 2025), https://www.metrc.com/information/metrc-and-biotrack-announce-strategic-partnership/.
³⁴ ‘Partnership’ or Consolidation?, supra notice 4.
³⁵ Metrc & BioTrack, Strategic Partnership Press Launch, supra notice 33.
³⁶ Id.
³⁷ ‘Partnership’ or Consolidation?, supra notice 4.
³⁸ New York Delays Marijuana Observe-and-Hint Till 2026 After Shock Deal, MJBizDaily (Sept. 10, 2025), https://mjbizdaily.com/following-surprise-deal-new-york-delays-cannabis-track-and-track-until-2026.
³⁹ Id.
⁴⁰ In poor health. Hashish Regulation Oversight Workplace, Procurements, https://hashish.illinois.gov/legal-and-enforcement/procurements.html.
⁴¹ Id.
⁴² Id.
⁴³ Estes v. Metrc, Inc., No. 3:25-cv-00556 (D. Or., filed Apr. 4, 2025).
⁴⁴ Metrc Permitting Rampant Unlawful Marijuana Exercise, Lawsuit Claims, MJBizDaily (Apr. 11, 2025), https://mjbizdaily.com/metrc-allowing-rampant-illegal-marijuana-activity-former-exec-claims-in-lawsuit/.
⁴⁵ Id.
⁴⁶ Id.
⁴⁷ Whistleblower Lawsuit Towards Hashish Agency Metrc Dismissed, MJBizDaily (June 10, 2025), https://mjbizdaily.com/whistleblower-lawsuit-against-cannabis-firm-metrc-dismissed/.
⁴⁸ California Hashish Regulation Information, January 2026 Information Bulletin (hashish.lacity.gov), supra notice 5.
⁴⁹ Id.
⁵⁰ Hashish Seed-to-Sale Is Turning into a Duopoly, CRB Monitor Information, https://information.crbmonitor.com/2023/05/cannabis-seed-to-sale-is-becoming-a-duopoly/.
⁵¹ New York Delays Marijuana Observe-and-Hint Till 2026, supra notice 38.
⁵² Id.
⁵³ N.Y. OCM, Press Launch: BioTrack Seed-to-Sale Monitoring (Nov. 18, 2024), https://hashish.ny.gov/system/recordsdata/paperwork/2024/11/bio-track-seed-to-sale-press-release.pdf.
⁵⁴ Rockland County Enterprise Journal, Hudson Valley Hashish Information (Jan. 2, 2026), https://rcbizjournal.com/2026/02/21/hudson-valley-cannabis-news/ (describing December 2025 lawsuit in opposition to OCM Metrc implementation).
⁵⁵ Mass. State Auditor’s Workplace, Audit of the Hashish Management Fee, supra notice 1.
⁵⁶ Mass. CCC, Massachusetts Grownup-Use Hashish Gross sales Generated $1.65 Billion Complete in 2025, supra notice 6.
⁵⁷ Mass. State Auditor’s Workplace, Overview of Audited Entity, supra notice 9.
⁵⁸ In Wake of Important Audit, Hashish Fee Shares Progress, WBUR (Aug. 19, 2025), https://www.wbur.org/information/2025/08/19/cannabis-commission-critical-audit.
⁵⁹ Id.
⁶⁰ Mass. State Auditor’s Workplace, Hashish Management Fee—Discovering 1, supra notice 8.
⁶¹ Id.
⁶² Mass. OIG, Letter from IG Shapiro to CCC Govt Director Ahern and Chair Stebbins (Mar. 27, 2025), https://www.mass.gov/doc/ccc-failed-to-collect-prorated-and-provisional-license-fees/obtain.
⁶³ Mass. OIG, OIG Finds Poor Administration at CCC Resulted in Failure to Accumulate Charges for Two Years, Press Launch (Mar. 27, 2025).
⁶⁴ State Inspector Basic Finds Hashish Management Fee Didn’t Accumulate As much as $1.75 Million in Licensing Charges, Boston Globe (Mar. 27, 2025).
⁶⁵ Mass. Inspector Basic Calls on Hashish Regulators to Conduct an Audit, CommonWealth Beacon (Mar. 28, 2025).
⁶⁶ Mass. State Auditor’s Workplace, Hashish Management Fee—Discovering 1, supra notice 8.
⁶⁷ 7 Key Takeaways from the Mass. Hashish Management Fee Audit, Boston.com (Aug. 21, 2025).
⁶⁸ Id.
⁶⁹ State Auditor Finds Widespread Mismanagement at Hashish Management Fee, Boston Globe (Aug. 14, 2025).
⁷⁰ Mass. State Auditor’s Workplace, Audit Identifies Mismanagement, Press Launch (Aug. 14, 2025).
⁷¹ Id.
⁷² Id.
⁷³ Mass. Gen. Legal guidelines ch. 94G, § 3.
⁷⁴ Mass. State Auditor’s Workplace, Audit of the Hashish Management Fee, supra notice 1.
⁷⁵ Id.
⁷⁶ Id.
⁷⁷ Mass. State Auditor’s Workplace, Overview of Audited Entity, supra notice 9.
⁷⁸ Mass. Gen. Legal guidelines ch. 94G, § 3; Mass. State Auditor’s Workplace, Audit of the Hashish Management Fee, supra notice 1.
⁷⁹ State Auditor Finds Widespread Mismanagement at CCC, Boston Globe, supra notice 69.
⁸⁰ Mass. Gen. Legal guidelines ch. 258; 815 CMR 5.00.
⁸¹ State Auditor Finds Widespread Mismanagement at CCC, Boston Globe, supra notice 69.
⁸² Hashish Fee Cites Progress in Wake of Important Audit, WBUR, supra notice 58; Mass. State Auditor’s Workplace, Hashish Management Fee—Discovering 1, supra notice 8.
⁸³ Mass. State Auditor’s Workplace, Hashish Management Fee—Discovering 1, supra notice 8 (company response noting hiring freeze efficient Might 2025 and MassCIP/MMJOS procurement standing).
⁸⁴ Mass. CCC, FY 2026 Finances Request Focuses on Important Business Points (Mar. 12, 2025), https://masscannabiscontrol.com/2025/03/massachusetts-cannabis-control-commission-fy-2026-budget-request-focuses-on-critical-industry-issues/.
⁸⁵ Mass. State Auditor’s Workplace, Hashish Management Fee—Discovering 1, supra notice 8 (SOPs created April 2025; SOC 2 audit preparation commenced).
⁸⁶ Mass. CCC, Hashish Management Fee Unanimously Approves Remaining Social Consumption Laws (Dec. 11, 2025), https://masscannabiscontrol.com/2025/12/massachusetts-cannabis-control-commission-unanimously-approves-final-social-consumption-regulations/.
⁸⁷ N.Y., Social Fairness Hashish Funding Fund, DASNY (2022), https://www.dasny.org/index.php/alternatives/rfps-bids/2022/new-york-social-equity-cannabis-investment-fund.
⁸⁸ Rosalind Adams, State Hashish Officers Repeatedly Raised Alarms, THE CITY (June 11, 2024).
⁸⁹ NYC Launches Social Fairness Hashish Mortgage Fund as State Pauses Its Program, CRB Monitor Information (July 5, 2024).
⁹⁰ Id.
⁹¹ Id.
⁹² Rosalind Adams, How Non-public Fairness Trumped Social Fairness in State Hashish Deal, THE CITY, supra notice 2.
⁹³ Adams, State Hashish Officers Repeatedly Raised Alarms, THE CITY, supra notice 88.
⁹⁴ Id.
⁹⁵ Adams, How Non-public Fairness Trumped Social Fairness, THE CITY, supra notice 2.
⁹⁶ NYC Launches Social Fairness Hashish Mortgage Fund, supra notice 89.
⁹⁷ Id.
⁹⁸ N.Y. Sen. Krueger and Rivera, Assertion on Considerations Concerning the NYS Hashish Social Fairness Fund (June 2024), https://www.nysenate.gov/newsroom/press-releases/2024/gustavo-rivera/senators-krueger-and-riveras-statement-concerns.
⁹⁹ Adams, How Non-public Fairness Trumped Social Fairness, THE CITY, supra notice 2.
¹⁰⁰ 2024 New York Hashish Fairness Wrapped, The Different Journal (Apr. 2, 2025).
¹⁰¹ NYC Launches Social Fairness Hashish Mortgage Fund, supra notice 89.
¹⁰² DASNY Faucets Non-public Fairness Agency Chicago Atlantic as Dispensary Landlord, Industrial Observer (Might 24, 2024).
¹⁰³ Id.
¹⁰⁴ NYC Launches Social Fairness Hashish Mortgage Fund, supra notice 89.
¹⁰⁵ Hudson Valley Hashish Information, Rockland County Enterprise Journal (Dec. 28, 2025), https://rcbizjournal.com/2025/12/26/hudson-valley-cannabis-news/.
¹⁰⁶ News10, Governor Says Hashish Dispensaries Will Not Face Closures, supra notice 7.
¹⁰⁷ Id.
¹⁰⁸ Rockland County Enterprise Journal, Hudson Valley Hashish Information (Feb. 21, 2026), https://rcbizjournal.com/2026/02/21/hudson-valley-cannabis-news/.
¹⁰⁹ New York Delays Marijuana Observe-and-Hint Till 2026, supra notice 38.
¹¹⁰ N.Y. OCM, Press Launch: BioTrack Seed-to-Sale Monitoring, supra notice 53.
¹¹¹ Id.
¹¹² N.Y. OCM, Seed-to-Sale (Metrc), https://hashish.ny.gov/seed-to-sale.
¹¹³ Id.
¹¹⁴ New York Delays Marijuana Observe-and-Hint Till 2026, supra notice 38.
¹¹⁵ Cal. State Auditor, Report No. 2025-048: Hashish Enterprise Licensing (Nov. 2025), https://www.auditor.ca.gov/stories/2025-048/.
¹¹⁶ Id.
¹¹⁷ Id.
¹¹⁸ Cal. State Auditor, Report Responses: 2024-048, https://www.auditor.ca.gov/stories/responses-2024-048-all/.
¹¹⁹ Cal. State Auditor, Report Responses: 2025-048, https://www.auditor.ca.gov/stories/responses-2025-048-all/.
¹²⁰ Cal. State Auditor, Report No. 2025-048, supra notice 115.
¹²¹ Id.
¹²² Id.
¹²³ THCFarmer, Metrc Lands $113M Deal to Proceed Hashish Monitoring Providers in California (July 2024).
¹²⁴ Id.
¹²⁵ California Hashish Regulation Information, January 2026 Information Bulletin, supra notice 5.
¹²⁶ Id.
¹²⁷ ArentFox Schiff, California’s Hashish Crackdown: File Seizures and Finances Reforms Purpose to Degree the Taking part in Area (Might 20, 2025), https://www.afslaw.com/views/alerts/californias-cannabis-crackdown-record-seizures-and-budget-reforms-aim-level-the; California Dep’t of Finance, Fund Situation Assertion: Hashish Management Fund (3288), Governor’s Finances 2025-26.
¹²⁸ Goodwin LLP, Bye-Bye 280E, supra notice 8.
¹²⁹ Wash. State Auditor’s Workplace, Evaluating Oversight, supra notice 3.
¹³⁰ Mass. OIG Letter, supra notice 62.
¹³¹ DASNY Faucets Chicago Atlantic as Dispensary Landlord, Industrial Observer, supra notice 102.
¹³² Id.
