Saint Kitts and Nevis Cannabis Regulations: Inside Regulation 55

What happens when a traceability regulation is written to track the money as well as the plants?

The Saint Kitts and Nevis cannabis regulations are contained in a single instrument, the Cannabis (Medicinal Cannabis Licensing) Regulations, published as SRO No. 17 of 2022. Part V of that instrument creates the St. Kitts and Nevis Tracking System. Regulation 55 sits inside Part V and requires the licensee’s money to be recorded in the same system as the plants, starting at the licence application.

What the Saint Kitts and Nevis Cannabis Regulations Require

The Saint Kitts and Nevis cannabis regulations are set out in SRO No. 17 of 2022, made under section 60 of the Cannabis Act, 2020 and published on 28 July 2022 in Extra-Ordinary Gazette No. 39 of 2022. Part V builds the St. Kitts and Nevis Tracking System, and regulation 55 requires the licensee’s money to be tracked inside it alongside the plants.

Regulation 1 gives the short title: “These Regulations may be cited as the Cannabis (Medicinal Cannabis Licensing) Regulations, 2022.” The enacting words cite the power: “In exercise of the power conferred by section 60 of the Cannabis Act, 2020, the Minister makes the following Regulations”. (The gazette prints the date as “28thJuly”.) The header reads “SAINT CHRISTOPHER AND NEVIS”, the formal name used in the instrument; this page uses Saint Kitts and Nevis in prose.

Regulation 5 lists nine licence categories at reg 5(1)(a) to (i): cultivation, dispensary, lounge, testing facility, processing and extraction, infused products manufacturer, transport, research, and import or export.

How Did the Cannabis Act, 2020 Become the Rulebook in Force Today?

The Cannabis Act, No. 8 of 2020 was assented on 14 February 2020 and commenced in stages: Parts I and II in April 2021, the Regulations published in July 2022, and the remaining Parts in April 2023.

Section 1(2) lets the Minister “appoint different dates for the coming into force of different Parts or sections of this Act.” The assent line reads “I assent, SAMUEL WEYMOUTH TAPLEY SEATON Governor-General. 14th February, 2020”, and the publication line “[Published 21st February 2020, Extra-Ordinary Gazette No. 13 of 2020.]”

SRO 13 of 2021, the Cannabis Act (Parts I and II) (Appointed Day) Order, 2021, carries no substantive rules: “Part I and Part II of the Act shall come into operation on the 30th day of April, 2021.” Part II holds section 4: subsection 4(1) establishes the Medicinal Cannabis Authority, and subsection 4(2) makes it “a body corporate”.

SRO No. 17 of 2022 followed on 28 July 2022. On 20 April 2023 the Government announced full activation of the Cannabis Act: “By the Cannabis Act (Parts III to VII) (Appointed) Day Order, published in the Gazette today, the Government has signalled its intent to clarify a responsible cannabis use and cannabis derivatives regulation regime within the Federation.” The Medicinal Cannabis Authority was launched on 25 April 2025.

Table A: Legislative timeline

What Does Part V of the Regulations Cover?

Part V is headed “St. Kitts and Nevis Tracking System” and runs from regulation 53 to regulation 62. It covers inventory tracking, unique identifiers, funds and money, weighing devices, reporting deadlines, loss of access, reconciliation, disaster continuity, and training.

Reg 53(1) sets the purpose: to “regulate, monitor, and track all Medicinal cannabis goods to eliminate diversion, inside and outside of the regulated Medicinal Cannabis system”. Money is not quarantined in reg 55. Reg 53(8) commits the Authority to update its tracking systems so the industry can “account for and monitor its medicinal cannabis inventory and all financial transactions and money”.

Traceability starts at “germinated seedling, clones or immature plants” under reg 54(5). Regs 54(11) and 54(12) tie a harvest batch UID to every plant UID inside it and goods UIDs back to their harvest batch, which makes this a seed-to-sale chain rather than batch-level reporting. Reg 61 writes continuity into the same Part, covering hurricane, flood and volcanic events.

Table B: Part V at a glance

What Does Regulation 55 Require?

Regulation 55 requires every financial transaction connected to a medicinal cannabis business, beginning at the licence application, to be recorded through the St. Kitts and Nevis Tracking System and made available to the Authority in read access format in real time. It runs to twenty sub-regulations and names seventeen transaction categories as a minimum.

Every financial transaction, beginning at the application

Two things follow. The start point is the application, before a licence exists. The access mode is real-time read access, not a periodic filing.

Reg 55(4) requires source of funds documentation at application for all monies to be invested. Reg 7(u)(i) shows the reach: funds in savings, checking or other accounts, listed with the institution’s name and address, “account type, account number, and the amount of money in the account”. Reg 7(f) adds proof of funds and reg 7(g) source of funds for every investment or capital expenditure.

Reg 55(2) carries the duty across the value chain, import and export included. Reg 55(1) gives the reason: to eliminate the diversion of funds and to meet “International obligations and guidelines related to anti-money laundering, combating the Financing of Terrorism”.

The Seventeen Categories of Recorded Transaction

Reg 55(6) opens with its controlling words: “Recorded Transactions related to the Medicinal cannabis business Operation shall include but may not be limited to the following”. That is a floor and not a ceiling.

The list runs from clause (a) to clause (q). Rent, salaries, loans, dividends, banking and capital expenditure are not entries a traceability audience expects in a traceability instrument.

The word “banking” appears exactly once in the whole of SRO No. 17 of 2022, at reg 55(6)(p). “Bank” as a word stem appears at reg 23(6), reg 96(9), reg 135(2)(h) and reg 136(1)(a).

Table C: Regulation 55(6), recorded transaction categories

Reg 55(6), sentence-cased for readability. The gazette wording is “shall include but may not be limited to the following”.

Who Can See the Data

Reg 55(9) gives the Authority “24-hour access to The St. Kitts and Nevis Tracking electronic database with real time view access to monitoring devices”. Reg 55(10) adds an Executive manager account for members of the Authority, with read access on every operational account, to investigate business records and financial transactions at any time.

Reg 55(3) requires the database to be “designed to flag irregularities” and opens it to any licensing authority and to a foreign law enforcement authority. Reg 55(8) requires the Division to inform the Authority immediately on any irregularity or suspicious finding. Reg 55(7) extends the documented chain of command to “all finances and monies”; reg 53(3) covers goods. The gazette says chain of command, not chain of custody, and this page quotes it as written.

Training, Tampering and Penalty

Reg 55(13) puts an “Anti-Money Laundering and Combating the Financing of Terrorism Course”, delivered with the office of National Drug and Money Laundering Control Policy, inside tracking-system training at every licensed medicinal cannabis business. Reg 62 bars anyone from using the system before completing the Authority’s training course.

Reg 55(11) makes tampering with the tracking system an offence “liable under section 57 of the Cannabis Act, 2020”; reg 53(7) does the same for the UID tags. Section 57 sets “a fine not exceeding fifty thousand dollars or to a term of imprisonment not exceeding 3 years” on summary conviction.

Regulation 55 Sub-Regulation Map

Regulation 55 has twenty sub-regulations. The table below maps each one to what it requires, with the gazette’s own wording as the anchor.

Table D: Regulation 55, sub-regulation by sub-regulation

Sub-regulations 55(14) to 55(20) restate reg 53(9) to 53(15) almost word for word, with “and financial transactions” added at 55(14). The account-governance regime built for plants was applied unchanged to money.

Table E: The reg 55 mirror of reg 53

Readers who work through statutes this way may want another single-article statute reference, or the Netherlands track and trace requirements.

Where Else Do the Regulations Reach Into a Licensee’s Finances?

Regulation 55 is the hub of the financial obligation, not the whole of it. Regulations 7, 23, 57, 96 and 135 to 137 each carry money duties of their own, from account disclosure at application through to seven-year retention of bank statements.

Reg 23(1) defines a financial interest as a profit-share agreement, an investment, a loan, or any other equity interest. Reg 23(3) catches profit-share employees, landlords on profit-share leases, consultants, agents such as accountants or attorneys, and commission salespeople, through every layer of a multi-layer structure. Reg 23(6)(a) carves out “a bank or financial institution whose interest constitutes a loan”, the line between ownership disclosure and loans to a cannabis business.

Money is an ordinary field of the activity record. Reg 57(2)(d) puts “total sale price or wholesale cost” into every activity record and reg 57(1)(d) puts applicable tax into the goods record. Reg 57(11) sets the clock: “all transactions shall be entered into the St. Kitts and Nevis Tracking System within 24 hours of occurrence.”

Reg 96(9) is a payment-routing rule inside an export regulation: transfer of payment for exported goods “to a bank or to an account of a consignee other than the consignee named in the export authorization, shall be prohibited.”

Reg 135(2) requires books and records for the current year and seven preceding calendar years, the preceding six months held on the licenced premises at all times, and reg 135(2)(h) names bank statements, tax records, contracts, purchase orders, sales invoices and sales receipts. Reg 135(1) requires both physical and electronic records.

Reg 136(1)(a) sets a seven-year floor on financial records. Under reg 136(4), “prior notice by the Authority to review records is not necessary” and the Authority “may review records outside of the licensee’s standard daily business hours.” Reg 137 requires a sales invoice or receipt for every sale or transfer, retained electronically and accessible to the Authority or any law enforcement authority.

How Do the Saint Kitts and Nevis Cannabis Regulations Compare With Other Traceability Mandates?

Traceability mandates usually stop at the plant and the package, and leave money to the banking system. Regulation 55 does not. The distinction is one of scope rather than of presence, because several traceability systems already capture price data at the point of sale.

A published vendor bulletin for a United States state traceability system sets out the fields used for in-person retail sales: total price, the listed shelf price, and the discount amount applied. Traceability systems do hold financial data.

Scope separates them. A retail sales-receipt price field records one transaction type at one point in the chain. Reg 55(6) reaches investments, capital expenditure, loans, rent, salaries, taxes, banking and dividends, and reg 55(5) starts the clock before a licence exists. The Saint Kitts and Nevis cannabis regulations are written so that the tracking system is also the financial record. That is not how most seed-to-sale mandates are drafted.

Correspondent banking access is a live concern for financial institutions across the Eastern Caribbean Currency Union. That context sits on our page about cannabis banking rather than here.

Readers comparing statutory drafting can see how other countries write their track-and-trace requirements set out separately, and cultivation licensing elsewhere in the OECS has its own guide.

What Do the Regulations Ask a Licensee to Do Day to Day?

Compliance with Part V is a set of standing operational duties, not a periodic filing exercise. The deadlines are measured in hours and days.

• An active tracking-system account before any commercial activity, reg 53(10) and reg 55(15).
• A designated account manager and a unique log-on per user, no sharing or transfer, reg 53(12)(b) and reg 55(17).
• Access rights cancelled within three calendar days of a user losing authorisation, reg 53(12)(d); errors corrected within three calendar days of discovery, reg 53(12)(e).
• Notifications monitored and resolved, not dismissed until resolved, reg 53(12)(f); compliance notifications resolved within five days, reg 53(12)(h).
• A record of all compliance notifications kept independent of the tracking system, reg 53(13) and reg 55(18).
• All transactions entered within 24 hours of occurrence, reg 57(11).
• Physical inventory reconciled to the database at least every 30 calendar days, reg 59(1); any discrepancy or break in the chain of command reported within 24 hours, reg 59(4).
• On loss of connectivity: notify the Authority immediately, stop moving goods until access is restored, keep manual records and back-enter, reg 58.
• Training completed before any person is authorized to use the system, reg 62, including the AML and CFT course under reg 55(13).

Where to Read the Regulation

The gazetted text is published by the Saint Kitts and Nevis Law Commission as a 148-page PDF.

• Instrument: Cannabis (Medicinal Cannabis Licensing) Regulations
• Citation: Statutory Rules and Orders No. 17 of 2022
• Published: 28 July 2022, Extra-Ordinary Gazette No. 39 of 2022
• Made under: section 60, Cannabis Act, No. 8 of 2020
• Regulator: Medicinal Cannabis Authority, established under s.4 of the Cannabis Act, No. 8 of 2020, Richard L. Caines Building, Princes Street, Basseterre, St. Kitts
• Full text: the Law Commission’s published copy of SRO No. 17 of 2022

Frequently Asked Questions

Carrying These Requirements in a System

A regulation drafted this way sets the specification for the software underneath it. A tracking system that satisfies Part V has to hold the plant record and the financial record in the same place, serve the regulator a real-time read view, and keep account governance tight enough to survive an enforcement conversation.

In practice: seed-to-sale genealogy under regs 54(11) and 54(12), transaction entry inside 24 hours under reg 57(11), 30-day reconciliation under reg 59(1), per-user log-ons and revocation windows under reg 55(17), and a regulator-side read view under regs 55(9) and 55(10).

Readers on the regulator side can compare this with government cannabis tracking elsewhere; operators comparing jurisdictions can review track-and-trace requirements by country. GrowerIQ builds seed-to-sale software for licensed producers and for the authorities that oversee them.

See how one system can carry plant records and financial records together: book a demo.

Last updated: August 2026

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