As Missouri's marijuana industry matures, operators are navigating a changing regulatory environment shaped by state oversight, federal uncertainty and growing competition. From the fallout of the Delta Extraction marijuana product recall to licensing enforcement and banking logistics, cannabis businesses are operating in a legal and compliance landscape that is constantly evolving.
"It's a tough business environment," said Husch Blackwell attorney Marshall Custer, who leads the firm's cannabis team. "You're selling a good that can be difficult to differentiate between your competitors … competition is getting a lot tougher than it used to be."
Among the most consequential regulatory moves of 2024 was the revocation of multiple microbusiness licenses. These licenses, intended to promote equity, faced intense scrutiny over real ownership and control.
"The Division of Cannabis Regulation has concluded that those licenses are not really controlled or majority-owned by the disadvantaged person," said Carnahan Evans attorney Joseph D. "Chip" Sheppard, who chairs the firm's cannabis/marijuana law group. "In reality, (they're) majority owned by somebody else … the actual minority-owned person is only having 10 or 20 percent of the benefits of the license."
Nine microbusiness licenses were revoked in March 2024, and DCR issued 32 additional "Notices of Pending Revocation." In many cases, the supposed majority owners had little knowledge of operations, signaling a broader crackdown on shell ownership structures. When the second round of microbusiness licensing was held in June 2024, Missouri expanded the number of awards from 48 to 57 to replace the nine initial revoked licenses. By April 2025, state officials have revoked 25 more microbusiness licenses for failure to meet ownership requirements.
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