Nine Missouri microbusiness cannabis facility licenses revoked due to ineligibility

To ensure the integrity of Missouri’s voter-approved regulatory program for microbusiness licenses, the Missouri Division of Cannabis Regulation (DCR) has revoked nine microbusiness dispensary licenses.

Article XIV outlines the intent of a microbusiness license as a cannabis business that will operate on a smaller scale than medical or comprehensive licenses and that the majority owner(s) must meet specific qualifications to be eligible. In addition, a microbusiness license is designed to provide a path to facility ownership for individuals who might not otherwise easily access that opportunity, such as those with a net worth of less than $250,000 or veterans with a service-connected disability. The microbusiness license must always be majority-owned and operated by individuals who meet these eligibility criteria. This means that DCR must continue to monitor the details of micro business ownership arrangements, even if they later change, to ensure these licenses remain in compliance.

On Dec. 15, 2023, DCR issued eleven Notices of Pending Revocation (NOPR) for microbusiness licensees that were awarded on Oct. 2, 2023. Each NOPR lists the basis for the pending revocation and prior to the Department revoking a license, the licensee has at least 30 days to cure the deficiencies listed in the notice and/or respond to the allegations and submit records or information demonstrating why the license should not be revoked or suspended. 

DCR determined that two licensees satisfied the NOPR by demonstrating that the licenses are and were majority-owned and operated by individuals who met the qualifications for ownership. One license was revoked due to an owner having a disqualifying felony offense with the revocation taking effect on March 11, 2024. The remaining eight licenses had numerous violations of the rule including providing false or misleading information in the application and failure to demonstrate that the microbusiness licenses were majority-owned and operated by eligible individuals, according to 19 CSR 100-1.190(1)(B)1-5 and Article XIV Section 2.4(12) and (13). The revocations took effect  March 27.

Throughout the application and verification process of the eight revoked licenses, the purported majority owners had limited to no knowledge or understanding of agreements or operations of the license and in some cases did not know the person who applied for the license on their behalf.

“While owning and operating a license may include contracting for management services or consulting services, the lack of knowledge, control, agency or decision-making demonstrated by the individuals whose information was used to meet eligibility does not meet even the most generous interpretation of owning and operating a business,” said Amy Moore, director of the Division of Cannabis Regulation. “These circumstances do not meet the intent or meaning of the requirement in Article XIV that micro businesses are operated by eligible individuals.”

Below is the status of the eleven microbusiness licenses that received a notice of pending revocation in December 2023: