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○preventing the growing of marijuana on public lands and the attendantpublic safety and environmental dangers posed by marijuana on publiclands; and○ preventing marijuana possession or use on federal property. 16 Theguidance emphasized that it expected states who authorize marijuana tohave “strong and effective regulatory and enforcement systems.” 17 Theymust be effective in practice in addition to the procedural and regulatoryeffect. 18The second memorandum, issued in February 2014, highlightedthe federal government’s priorities on financial crimes associate withrecreational marijuana. 19Finally, in October 2014, the Department of Justice issued a guidance for tribal lands.Enforcement would be determined on a case by case basis with consultation with tribalpartners and will focus upon the eight priorities from the “Cole Memo. 202. Federal Drug Free Workplace Act. 21The Federal Drug Free Workplace Act requires all federal grantees and some federalcontractors 22 to implement a “zero tolerance” drug policy. 23This means that once an16 “Cole Memo” 06/29/201317 “Cole Memo” 06/29/201318 “Cole Memo” 06/29/201319 “Cole Memo” 02/14/201420 Policy Statement Regarding Marijuana Issues in Indian Country. 10/28/201421 41 U.S.C. § 8101 et seq.

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