Private equity’s drug war profiteering

Private equity and the drug war
In May, the Private Equity Stakeholder Project participated in a panel hosted by Drug Policy Alliance on the topic of privatization and the war on drugs. Private equity firms have profited from drug policy and the drug war through ownership of opioid treatment programs, contracts to both provide healthcare and exploit labor in prisons and jails, as well as providing loans, leases, and services in the increasingly semi-legal U.S. cannabis industry.

A through-line in private equity’s drug war profiteering has been the industry’s efforts to shape public policy — using the political power attached to wealth — sometimes in conflict with public health and medical experts.

Private equity fights to limit methadone access
Nearly one-third of U.S. methadone clinics are owned by private equity firms, according to reporting from STAT News, highlighting how private equity can profit from an ongoing public health crisis. Additionally, large private equity-owned chains have intensely lobbied to protect their profits and market power and limit access to methadone, opposing reforms supported by lawmakers, public health experts, and doctors to expand access to the important medication.[1]

Methadone is used to treat opioid use disorder (OUD) by reducing opioid craving and withdrawal, as well as blunting or blocking the effects of opioids. Methadone is approved by the Food and Drug Administration to treat OUD and pain management and is considered safe and effective when taken as prescribed.[2]

A bipartisan bill introduced in Congress in early 2023, called the “Modernizing Opioid Treatment Access Act,” would allow board certified and Department of Drug Enforcement (DEA)-registered addiction doctors to prescribe methadone that patients would be able to pick up at a pharmacy.[3] Currently, methadone can only be distributed in extremely limited clinical settings under strict federal and state regulation. The proposed law could increase methadone access to an additional 43.5 million people in the U.S. (14% more than under the current rules), according to one group of researchers.[4]

The strongest opposition to expanding methadone access has been from doctors and executives at clinics owned by private equity and their trade group, the American Association for the Treatment of Opioid Dependence (AATOD).[5] “The number one ask,” said one lobbyist at a recent industry conference, “is [to] oppose the Modernizing Opioid Treatment Access Act.” AATOD’s founder, Mark Parrino, had similar sentiments on the bill: “We think this is the wrong way to go.”[6]

Another trade group, Advocates for Opioid Addiction Treatment, has opposed expanding access to methadone treatment. Five of the group’s seven members are private equity-owned, including BayMark Health Services, Behavioral Health Group, Community Medical Services, Crossroads Treatment Centers, and New Season. Another member, Acadia Healthcare, was owned by private equity firm Waud Capital Partners until 2017 — Waud’s founder and managing director serves as chairman of Acadia’s board.[7]

Doctors vs. private equity
Almost one in three people in the U.S. report knowing someone who has died of a drug overdose, according to one study published in May.[8] There have been more than 100,000 drug overdose deaths each year since 2020.[9] Opioid-involved overdose deaths increased from 49,860 in 2019 to 81,806 in 2022.[10]

The American Medical Association supports expanded methadone access through legislation, noting that lack of access to substance use disorder (SUD) treatment contributes to existing racial and gender inequalities, especially in rural areas.[11] The American Society of Addiction Medicine has also supported expanding access to methadone, saying that statements from opponents “are misleading, illogical, and put more patients with OUD [opioid use disorder] at risk for overdose in a time of an unprecedented death toll.”[12]

The groups fighting against more access to methadone represent a broader concern: Private equity firms have long utilized lobbying and industry groups as political pressure aimed towards protecting profits — sometimes at the expense of public health. In addition to methadone, private equity-affiliated groups have dedicated lobbying efforts to influencing hospital acquisition rules, physician practice consolidation, independent practice regulations, and legislation regulating surprise billing..

Private equity in prisons: healthcare
Private equity firms have gained from the drug war by investing in services which support mass incarceration. In the four decades leading up to 2019, the U.S. prison population reached 1.43 million, with one in five incarcerated people listing a drug offense as their most serious crime.[13]

A handful of private equity firms have invested in correctional services including healthcare, food, commissary, electronic monitoring, and telecommunication — touching almost every part of life within U.S. prisons and jails.[14]

Two of the largest U.S. correctional healthcare companies, private equity-owned Wellpath (formerly Correct Care Solutions) and YesCare (formerly Corizon Health), have been scrutinized for providing inadequate care, understaffing, and cost-cutting at patients’ expense.[15]

In some cases, public officials may be constrained by limited choices into contracting with a company with known problems. Local authorities have had limited options against Wellpath in states including California, Georgia, Indiana, Michigan, New York, Oregon, Pennsylvania, Tennessee, Texas, Vermont, Wisconsin, and Washington.

Media reports have highlighted relationships between Wellpath and local public officials throughout the U.S., including in Alameda, Monterey, San Diego, Santa Barbara, Ventura (California); Loudon, Norfolk (Virginia); Hudson (New Jersey); Charleston (South Carolina); and Westchester (New York).

In recent years, Wellpath has lost multiple local contracts, including its contract to run hospitals in  Alaska and New Hampshire as well as at correctional centers inMassachusetts, New Orleans, and Texas. The company has also opted to terminate several unprofitable contracts.[16] In some small rural counties, Wellpath has left after being unable to meet its profit targets.[17]

YesCare/Corizon has lost its contracts in Arizona, Georgia, Idaho, Indiana, Kansas, Maryland, Michigan, Minnesota, Missouri, New Mexico, Tennessee, Virginia, Wyoming, and at New York City’s Rikers Island. The company has been in bankruptcy proceedings for more than a year in a case related to its use of a controversial process known as the Texas Two-Step, in which a company divides into multiple entities and places its liabilities into a shell company, which later declares bankruptcy.[18]

Private equity in prisons: cheap labor
Private equity firms may have also had help from public authorities in exploiting prison labor.

One recent class action lawsuit accuses a slew of Alabama officials, cities, and companies of human trafficking, racketeering, and violating the Ku Klux Klan Act. The suit was filed by incarcerated individuals, labor lawyers, and unions, and argues that Alabama government officials have colluded to keep Black people imprisoned as cheap labor. The lawsuit seeks “to abolish a modern-day form of slavery.”[19]

Incarcerated workers for one company, frozen food supplier Southeastern Meats, could work up to 12-hour shifts in 30-some-degree cold, according to Bloomberg.[20] Southeastern Meats has been owned by private equity firm Borgman Capital since 2021.[21]

A recent investigation by AP News found that U.S. prisoners are linked to hundreds of popular food brands.[22] The ACLU has estimated that at least 791,500 people incarcerated in the U.S. perform work as part of their incarceration and are paid an average maximum hourly wage of 52 cents.[23]

Wellpath-owner H.I.G. Capital also uses incarcerated labor through its portfolio company TKC Holdings.[24] TKC Holdings owns Trinity Services Group, which uses incarcerated labor – including “more than 7,500 offender workers” – in addition to its own employees to make food in prisons and jails.[25] Trinity has been criticized for poor food quality, which was so bad at one facility that correctional officers expressed concerns it could start a riot.[26] The company was also penalized over $2 million for understaffing in Michigan between 2015 and 2017.[27]

Private equity and cannabis: steep lending scheme
Private equity can also undermine purported social equity efforts. New York City recently enlisted a private equity firm to be landlord and lender for cannabis dispensaries operated by people with drug convictions. The private equity firm, Chicago Atlantic Group, agreed to buy properties for dispensaries and issue upstart loans to dispensary operators.[28] Loan documents revealed that interest for loans could reach up to an 18% rate if an operator defaults on the lease’s terms.[29]

The program puts substantial risk on borrowers and taxpayers and guarantees benefits for the private equity firm, allowing Chicago Atlantic to seize properties from operators who make late payments.[30]

Dispensary operators have expressed concerns about defaulting on their loans, according to THE CITY, which describes the arrangement as a “lopsided deal that undermines its commitment to social equity goals while guaranteeing substantial returns to its partner, private equity firm Chicago Atlantic Group.”[31]

Chicago Atlantic Group has already established a significant foothold in the cannabis industry. As of March 2022, the private equity firm had issued more than $1.2 billion in loans to companies involved in cannabis farming, production, and retail operations.[32] Chicago Atlantic Group sponsors and manages Chicago Atlantic Real Estate Finance, a mortgage REIT that issues loans to U.S. cannabis operators.[33]

Private equity and cannabis: foothold in a semi-legal industry

The cannabis industry has flourished despite the drug still being federally controlled. In total, cannabis markets are estimated to add $112.4 billion to the U.S. economy in 2024.[34]

Some have noted that those most impacted by the drug war have also been excluded from the wealth created as cannabis becomes increasingly legal.[35] Several U.S. cities have struggled to establish programs that help disadvantaged people launch cannabis businesses.[36] One commentator has noted “the emergence of a profitable cannabis market may not necessarily challenge economic and racial inequalities across society.”[37]

Communities have continued to face criminal enforcement against cannabis, despite its semi-legal status. In New York City, as of June, a mayoral task force had conducted police sweeps on hundreds of shops in search of unlicensed cannabis sales.[38] New York legalized recreational cannabis in 2021 but has been slow to issue dispensary licenses.[39] As of June 2024, officials estimate there are 2,800 unlicensed cannabis shops in New York City, compared to legal 58 shops.[40]

One year ago, a partner from cannabis investor Chicago Atlantic discussed New York’s unlicensed cannabis market on a podcast. “…there’s really no crackdown, there’s no real push to let’s incarcerate, let’s shut down these black market operators that are selling out of trucks.”[41]

More than six million cannabis-related arrests occurred from 2010 to 2018, according to a report from ACLU, which found that Black people are far more likely than white people to be arrested for cannabis possession in every state, including states that have passed legalization measures.[42] U.S. drug laws have been selectively enforced — primarily along racial lines — for more than a century.[43]

According to FBI data, nearly a quarter million arrests were reported — a significant underestimate — for cannabis-related violations in 2022.[44] The same year, Fortune described how “Black cannabis entrepreneurs account for less than 2% of the nation’s marijuana business.”[45]

Cannabis is currently listed as a Schedule I controlled substance, making possession a crime.[46] As of late 2023, 24 states, three U.S. territories, and the District of Columbia had measures regulating recreational cannabis use.[47] In May 2024, the Justice Department formally moved to reclassify cannabis as a less dangerous drug.[48]

Chicago Atlantic responded describing the tax gains to be reaped from the proposal (“This is expected to provide significant financial benefits for cannabis operators by reducing the tax burden and allowing for debt cost deductions.”).[49] The firm stands to build on its existing cannabis lending business: “Over the past six years, Chicago Atlantic has led the industry in providing debt capital to many of the market’s strongest operators,” said one partner in response to the announcement to reschedule cannabis, “and we are eager to grow alongside our clients.”[50]

People can still be subject to criminal charges under the Justice Department proposal. Schedule III status allows for some medical uses and the prosecution of anyone who traffics in the drug without permission.[51]

Private equity has profited from the increasingly legal cannabis industry through adjacent services. GardaWorld, which is owned by BC Partners,[52] offers “cannabis security services” including armed transportation, alarm monitoring, video surveillance, and loss prevention. The company also helps dispensary operators to become licensed, recruit staff, and perform other services.[53]

Private equity firms can also gain by policing the boundaries of legal cannabis markets and preventing unlicensed trade. Allied Universal – owned by Warburg Pincus[54] – is the largest provider of canine drug detection teams in the world, employing more than 900 dogs.[55]

Wrapping up
Private equity firms have profited from drug policy and the drug war through various methods, including addiction treatment, prison healthcare and incarcerated labor, and loans to new cannabis companies in an increasingly legalized industry. The private equity industry has acted in response to shifting laws and regulations, and sometimes exercised influence over public policy.

Policymakers should take note of how private equity firms behave in a shifting drug policy environment – and ensure that private equity firms do not undermine efforts to redress past injustices, and that they do not help perpetuate existing inequalities which have been created and reinforced over the decades-long war on drugs.

Resources

[1] Lev Facher. “The Methadone Clinic Monopoly: Opioid Treatment Chains Backed by Private Equity Are Fighting Calls for Reform.” STAT, March 19, 2024. https://www.statnews.com/2024/03/19/methadone-clinics-opioid-addiction-private-equity/.

[2] Substance Abuse and Mental Health Services Administration. “Methadone,” March 29, 2024. https://www.samhsa.gov/medications-substance-use-disorders/medications-counseling-related-conditions/methadone.

[3] Senator Edward Markey. “Senators Markey, Paul Celebrate Bipartisan Committee Passage of Lifesaving Methadone Expansion Legislation | U.S. Senator Ed Markey of Massachusetts,” December 12, 2023. https://www.markey.senate.gov/news/press-releases/senators-markey-paul-celebrate-bipartisan-committee-passage-of-lifesaving-methadone-expansion-legislation.

[4] Chris Larson. “Proposed Law Would Increase Methadone Access for 43.5M Americans.” Behavioral Health Business, January 10, 2024. https://bhbusiness.com/2024/01/10/proposed-law-would-increase-methadone-access-for-43-5m-americans/.

[5] Lev Facher. “The Methadone Clinic Monopoly: Opioid Treatment Chains Backed by Private Equity Are Fighting Calls for Reform.” STAT, March 19, 2024. https://www.statnews.com/2024/03/19/methadone-clinics-opioid-addiction-private-equity/.

[6] Lev Facher. “At Las Vegas Conference, Methadone Clinics Blast Idea of Doctors Prescribing Directly.” STAT, May 28, 2024. https://www.statnews.com/2024/05/28/addiction-methadone-clinics-doctor-prescription-markey/.

[7] Lev Facher. “The Methadone Clinic Monopoly: Opioid Treatment Chains Backed by Private Equity Are Fighting Calls for Reform.” STAT, March 19, 2024. https://www.statnews.com/2024/03/19/methadone-clinics-opioid-addiction-private-equity/.

[8] Alene Kennedy-Hendricks, Catherine K. Ettman, and Sarah E. Gollust. “Experience of Personal Loss Due to Drug Overdose Among US Adults.” JAMA Health Forum, May 31, 2024. https://jamanetwork.com/journals/jama-health-forum/fullarticle/2819328.

[9] Jan Hoffman. “Overdose Deaths Dropped in U.S. in 2023 for First Time in Five Years.” The New York Times, May 15, 2024. https://www.nytimes.com/2024/05/15/health/drug-overdose-deaths.html.

[10] National Institute on Drug Abuse. “Drug Overdose Death Rates | National Institute on Drug Abuse (NIDA),” May 14, 2024. https://nida.nih.gov/research-topics/trends-statistics/overdose-death-rates.

[11] American Medical Association. “Advocating for Communities: Increasing Access to Treatment for Substance Use Disorder,” 2024. https://www.ama-assn.org/system/files/2024-mac-sud-issue-brief.pdf.

[12] American Society of Addiction Medicine. “Support Letter for the Modernizing Opioid Treatment Access Act,” June 30, 2023. https://downloads.asam.org/sitefinity-production-blobs/docs/default-source/advocacy/letters-and-comments/methadone-resources/30.06.23_motaa-explainer.pdf?sfvrsn=e08d098e_1.

[13] Aaron Morrison. “50-Year War on Drugs Imprisoned Millions of Black Americans.” PBS News, July 26, 2021. https://www.pbs.org/newshour/nation/50-year-war-on-drugs-imprisoned-millions-of-black-americans.

[14] Private Equity Stakeholder Project. “From Dawn ‘Til Dusk: Private Equity’s Impact on Incarceration,” September 13, 2023. https://pestakeholder.org/news/from-dawn-til-dusk-private-equitys-impact-on-incarceration/.

[15] U.S. Senators Warren, Markey. “Warren, Markey Urge Massachusetts Department of Correction to Carefully Review Corizon and Wellpath Bids and Maximize Accountability of Health Services Provider in State Prisons,” February 14, 2024. https://www.warren.senate.gov/newsroom/press-releases/warren-markey-urge-massachusetts-department-of-correction-to-carefully-review-corizon-and-wellpath-bids-and-maximize-accountability-of-health-services-provider-in-state-prisons; Tuhin Chakraborty. “When Healthcare Doesn’t Care.” The Flaw, February 13, 2024. https://theflaw.org/articles/when-healthcare-doesnt-care/; Marsha McLeod. “The Private Option.” The Atlantic, September 12, 2019. https://www.theatlantic.com/politics/archive/2019/09/private-equitys-grip-on-jail-health-care/597871/.

[16] Danny Robbins and Carrie Teegardin. “Ga. Prison Medical Provider Cites Millions in Extra Costs Due to Violence.” Corrections1, February 16, 2024. https://www.corrections1.com/correctional-healthcare/ga-prison-medical-provider-cites-millions-in-extra-costs-due-to-violence; Ryan Oehrli. “Health Care Company Wants out of Contract for Mecklenburg Jail Inmate Services.” The Charlotte Observer, February 6, 2024. https://ca.news.yahoo.com/health-care-company-wants-contract-143347509.html; Brian Gawley. “Clallam County to Hire Jail Nurses after Service Provider Ends Contract.” Peninsula Daily News, February 14, 2024. https://www.peninsuladailynews.com/news/clallam-county-to-hire-jail-nurses-after-service-provider-ends-contract/; Nicole Montesano. “Jail Scrambles for New Medical Provider after Wellpath Pulls Out.” News-Register.com, August 18, 2023. http://newsregister.com/article?articleTitle=jail-scrambles-for-new-medical-provider-after-wellpath-pulls-out–1692377744–46828–; Amy Passaretti Willis. “Healthcare Provider for Pender County Jail Bows out, Commissioners to Vote on New Firm.” Port City Daily, October 15, 2022. https://portcitydaily.com/local-news/2022/10/15/healthcare-provider-for-pender-county-jail-bows-out-commissioners-to-vote-on-new-firm/.

[17] Brian Gawley. “Clallam County to Hire Jail Nurses after Service Provider Ends Contract.” Peninsula Daily News, February 14, 2024. https://www.peninsuladailynews.com/news/clallam-county-to-hire-jail-nurses-after-service-provider-ends-contract/.

[18] Dietrich Knauth. “Prison Health Co. May Stay in Bankruptcy, but Needs New Deal, Judge Rules | Reuters.” Reuters, April 11, 2024. https://www.reuters.com/legal/litigation/prison-health-co-may-stay-bankruptcy-needs-new-deal-judge-rules-2024-04-11/.

[19] Josh Eidelson. “Cheap Prison Labor Is Keeping People Locked Up Longer, Suit Alleges.” Bloomberg, May 11, 2024. https://www.bloomberg.com/news/features/2024-05-11/us-prison-labor-powers-billions-in-corporate-government-revenue.

[20] Josh Eidelson. “Cheap Prison Labor Is Keeping People Locked Up Longer, Suit Alleges.” Bloomberg, May 11, 2024. https://www.bloomberg.com/news/features/2024-05-11/us-prison-labor-powers-billions-in-corporate-government-revenue.

[21] Borgman Capital. “Private Equity Firm, Borgman Capital, Acquires Southeastern Meats Inc.,” May 28, 2021. https://static1.squarespace.com/static/5ed6a14f06f98938d0a73713/t/60b8fd6bf0a860736c879e81/1622736236451/Edited+SEMeats+Press+Release.pdf.

[22] Robin McDowell and Margie Mason. “Prisoners in the US Are Part of a Hidden Workforce Linked to Hundreds of Popular Food Brands.” AP News, January 29, 2024. https://apnews.com/article/prison-to-plate-inmate-labor-investigation-c6f0eb4747963283316e494eadf08c4e.

[23] American Civil Liberties Union and the University of Chicago Law School Global Human Rights Clinic. “Captive Labor: Exploitation of Incarcerated Workers,” June 15, 2022. https://www.aclu.org/wp-content/uploads/publications/2022-06-15-captivelaborresearchreport.pdf, p. 10.

[24] Fola Akinnibi. “Prison Food Is the Latest Target in a Campaign to Divest Holdings.” Los Angeles Times, November 30, 2019. https://www.latimes.com/business/story/2019-11-30/prison-food-is-latest-target-in-campaign-to-divest-holdings.

[25] TKC Holdings. “Companies.” Accessed July 25, 2024. https://www.tkcholdings.com/companies/; Trinity Services Group. “Home.” Accessed July 25, 2024; https://trinityservicesgroup.com/. Trinity Services Group. “Food Service.” Accessed July 25, 2024. https://trinityservicesgroup.com/food-service/.

[26] Lucas Daprile. “Cuyahoga Could End Inmate Kitchen Labor under Agreement with Troubled Jail Food Provider.” Cleveland.com, September 20, 2023. https://www.cleveland.com/cuyahoga-county/2023/09/cuyahoga-could-end-inmate-kitchen-labor-under-agreement-with-troubled-jail-food-provider.html.

[27] Paul Egan. “Prison Food Contractor Hit with $2M in Penalties.” Detroit Free Press, January 20, 2017. https://www.freep.com/story/news/local/michigan/2017/01/20/prison-food-contractor-hit-2m-penalties/96824274/.

[28] Abigail Nehring. “DASNY Taps Private Equity Firm Chicago Atlantic as Dispensary Landlord.” Commercial Observer, May 23, 2024. https://commercialobserver.com/2024/05/chicago-atlantic-cannabis-landlord/.

[29] Rosalind Adams. “NY Promised Pot Store Loans Would Build Wealth and Create Equity. Instead, They’re Loading Businesses With Steep Costs.” THE CITY – NYC News, November 16, 2023. http://www.thecity.nyc/2023/11/16/marijuana-store-loans-licensed-cannabis-management-chicago-atlantic-dormitory-authority/.

[30] Adam Jackson. “Report: Chicago Atlantic May Be the Biggest Winner in New York Rollout.” Green Market Report, April 25, 2024. https://www.greenmarketreport.com/report-chicago-atlantic-may-be-the-biggest-winner-in-new-york-rollout/.

[31] Rosalind Adams. “How Private Equity Trumped Social Equity in State Cannabis Deal.” THE CITY – NYC News, April 24, 2024. http://www.thecity.nyc/2024/04/24/cannabis-fund-social-equity-dispensary/.

[32] Carrie Pallardy. “Cannabis Debt Lender Chicago Atlantic Targets Single and Dual…” New Cannabis Ventures, March 30, 2022. https://www.newcannabisventures.com/cannabis-debt-lender-chicago-atlantic-targets-single-and-dual-state-operators/.

[33] Chicago Atlantic Real Estate Finance, Inc. “Home.” Accessed July 15, 2024. https://www.refi.reit/.

[34] Andrew Long. “Marijuana Industry Will Add $112.4 Billion to US Economy in 2024.” MJBizDaily, April 24, 2024. https://mjbizdaily.com/marijuana-industry-will-add-112-4-billion-to-us-economy-in-2024-mjbiz-factbook/.

[35] Benjamin Yen-Yi Fong. “Ganjapreneurs and the Caucasian Cannabis Cartel.” Verso, September 11, 2023. https://www.versobooks.com/blogs/news/ganjapreneurs-and-the-caucasian-cannabis-cartel.

[36] Sophie Quinton. “Black-Owned Pot Businesses Remain Rare Despite Diversity Efforts.” Stateline, January 15, 2021. https://stateline.org/2021/01/15/black-owned-pot-businesses-remain-rare-despite-diversity-efforts/.

[37] Kojo Koram. “Cannabis and Capitalism: The Question of Ownership WIthin Drug Policy Reform.” Common Wealth, April 20, 2020. https://www.common-wealth.org/interactive/cannabis-and-capitalism.

[38] Rosalind Adams. “Video of NYPD Cannabis Raid and Arrest Raises Questions About Adams’ New Enforcement Offensive.” THE CITY – NYC News, June 3, 2024. http://www.thecity.nyc/2024/06/03/video-nypd-cannabis-raid-adams-hochul/.

[39] Jennifer Peltz and Bobby Caina Calvan. “New York Hasn’t Licensed Any Pot Shops, yet They Abound | AP News.” AP News, November 18, 2022. https://apnews.com/article/new-york-city-brooklyn-marijuana-recreational-4a602790df5c6698e49b723ac5fa4b14.

[40] Rosalind Adams. “Video of NYPD Cannabis Raid and Arrest Raises Questions About Adams’ New Enforcement Offensive.” THE CITY – NYC News, June 3, 2024. http://www.thecity.nyc/2024/06/03/video-nypd-cannabis-raid-adams-hochul/.

[41] David Spray. “Ep044: Returns on an Alternative Investment Class with Hayden Kelly.” The IC-DISC Show, June 28, 2023. https://www.ic-discshow.com/044.

[42] American Civil Liberties Union. “A Tale of Two Countries: Racially Targeted Arrests in the Era of Marijuana Reform,” April 16, 2020. https://www.aclu.org/publications/tale-two-countries-racially-targeted-arrests-era-marijuana-reform.

[43] Jamila Hodge and Nazish Dholakia. “Fifty Years Ago Today, President Nixon Declared the War on Drugs.” Vera Institute of Justice, July 7, 2018. https://www.vera.org/news/fifty-years-ago-today-president-nixon-declared-the-war-on-drugs.

[44] Iris Dorbian. “Weed Arrests Were Nearly A Quarter Million Last Year, Per FBI Data.” Forbes, October 19, 2023. https://www.forbes.com/sites/irisdorbian/2023/10/19/weed-arrests-were-nearly-a-quarter-million-last-year-per-fbi-data/.

[45] Amiah Taylor. “Black Cannabis Entrepreneurs Account for Less than 2% of the Nation’s Marijuana Businesses | Fortune.” Fortune, April 26, 2022. https://fortune.com/2022/04/26/black-cannabis-entrepreneurs-marijuana-businesses-marijuana-laws/.

[46] Lisa N. Sacco. “The Schedule I Status of Marijuana.” Congressional Research Service, October 7, 2022. https://crsreports.congress.gov/product/pdf/IN/IN11204.

[47] National Conference of State Legislatures. “State Medical Cannabis Laws,” June 4, 2024. https://www.ncsl.org/health/state-medical-cannabis-laws.

[48] Lindsay Whitehurst. “Justice Department Formally Moves to Reclassify Marijuana as a Less Dangerous Drug in Historic Shift.” AP News, May 16, 2024. https://apnews.com/article/marijuana-rescheduling-drug-policy-biden-15b43441670757b0c2bfa36731e47d07.

[49] Steven Ernest. “Rescheduling Reveals the Double Tax Advantage of Debt : Chicago Atlantic.” Chicago Atlantic, May 28, 2024. https://www.chicagoatlantic.com/rescheduling-reveals-the-double-tax-advantage-of-debt/.

[50] Libby Arlen. “The Cannabis Industry Reacts to DEA Rescheduling Announcement.” Greenway Magazine, May 1, 2024. https://mogreenway.com/2024/05/01/the-cannabis-industry-reacts-to-dea-rescheduling-announcement/.

[51] Joyce Orlando. “Marijuana Could Soon Be Reclassified. So Just What Is a Schedule 3 Drug?” The Tennessean, May 1, 2024. https://www.tennessean.com/story/news/2024/05/01/what-is-a-schedule-3-drug-marijuana-classification-change/73526170007/.

[52] BC Partners. “GardaWorld.” Accessed July 15, 2024. https://www.bcpartners.com/private-equity-strategy/portfolio/gardaworld/.

[53] GardaWorld. “Cannabis Security Services.” Accessed July 15, 2024. https://www.garda.com/lp/cannabis-security-services.

[54] Warburg Pincus. “Allied Universal.” Accessed July 15, 2024. https://warburgpincus.com/investments/allied-universal/.

[55] PR Newswire. “A Dog’s Nose Knows! Allied Universal Canine Team Stops 250 Pounds of Marijuana From Hitting the Streets in the U.S.,” October 20, 2023. https://markets.businessinsider.com/news/stocks/a-dog-s-nose-knows-allied-universal-canine-team-stops-250-pounds-of-marijuana-from-hitting-the-streets-in-the-u-s-1032725099.