By: Kourtney Blomberg, Bureau of Investigations and Enforcement
The Division of Cannabis Regulation (DCR) works to support a safe, well-regulated cannabis industry by helping licensees understand and meet Missouri’s regulatory requirements. DCR’s compliance approach emphasizes education, clear communication and timely correction of identified issues. When a compliance concern is identified, DCR communicates with the licensee about the issue, applicable requirements and any actions needed to address it. The goal is to resolve the concerns as early as possible, prevent recurrence and support the licensee’s return to and continued compliance.
DCR recently published the Path to Compliance Guide: Corrective Actions and Expectations. The guide provides licensees with information about DCR’s compliance processes, including types of notices, response expectations, timelines, corrective actions, and potential enforcement matters.
Corrective actions range from warnings and notices of violation to fines, suspensions and even license revocation and do not always start with a warning but are based on the totality of the circumstances. These notices are issued to licensee’s Designated Contact, and all deadlines are measured using calendar days beginning the day after the date the notice is received.
Compliance Notices
Educational Warnings address minor issues and do not require a licensee to follow-up with DCR. Initial Notices of Violation (INOVs) outline rule violations and necessary remedial actions, along with a written response from the licensee. If issues remain unresolved, a Final Notice of Violation (FNOV) is issued, providing 30 days for correction before penalties may be applied. An Educational Warning does not have to be issued before an INOV. Repeat violations may also require additional corrective measures, such as quality management system accreditation or third‑party audits.
Other notice types include Notices of Investigation, which require record preservation during active investigations, and Administrative Holds, which freeze all activity involving specific products until compliance concerns are resolved.
Penalties and Enforcement
DCR may impose fines, restrict/limit, suspend, or revoke a license depending on the severity of a violation. Fine amounts vary by rule and can reach up to $50,000 to $100,000 for serious track‑and‑trace or sampling and testing or issues. During a suspension, the licensee must cease operations immediately and ensure all product is safely secured. Revocations formally conclude all licensed activity, and unauthorized possession may violate state law.
Appeals
Licensees may appeal any penalty to the Administrative Hearing Commission, an independent administrative tribunal responsible for reviewing disputes between state agencies and affected parties (licensees). Complaints must be submitted by the Licensee within 30 days of the decision.
Commitment to Compliance
Successful compliance depends on clear communication and a shared understanding of regulatory expectations. Licensees are encouraged to stay informed of current requirements, maintain accurate records, respond promptly to DCR communications and address identified concerns in a timely manner.
DCR encourages licensees to ask questions when requirements or requested corrective actions are unclear. Questions about a specific compliance notice should be directed to the DCR representative listed in the communication.
