Montana DOR Cannabis Control Division Fines Dispensary $12,500 for Delivering Cannabis Without a Delivery Endorsement (March 2025)

The Montana Department of Revenue Cannabis Control Division fined a Helena-area dispensary $12,500 after investigators confirmed the licensee had conducted 47 home-delivery transactions over a 30-day period without holding the required Delivery Endorsement to its adult-use dispensary license.

Montana Delivery License Requirements

Under MCA § 16-12-214 and ARM 42.39.704, Montana adult-use cannabis dispensaries that wish to offer home delivery must obtain a Delivery Endorsement from the Cannabis Control Division. The endorsement requires an additional application, background checks for all delivery personnel, vehicle registration, and a delivery tracking protocol using the state seed-to-sale system.

Investigation Summary

Following an anonymous tip in February 2025, Cannabis Control Division compliance investigators reviewed the respondent's state tracking records and identified 47 cannabis sales transactions between January 5 and February 3, 2025, that were recorded as delivery transactions. The respondent's license did not include a Delivery Endorsement.

Investigators confirmed via GPS data subpoena that at least 32 of the 47 transactions corresponded to delivery routes originating from the licensed dispensary location.

Civil Penalty

Under ARM 42.39.102, unauthorized delivery activities are subject to a civil penalty of:

$250 per transaction for first-offense delivery without endorsement
$500 per transaction for repeat violations

The Division calculated the penalty on 47 transactions at $250 each = $11,750, rounded to $12,500 under the Division's aggravation schedule for non-cooperation during the investigation.

Corrective Action Required

The dispensary must:

Immediately cease all delivery operations until a Delivery Endorsement is obtained and effective
Apply for a Delivery Endorsement within 30 days
Implement a delivery tracking protocol satisfying ARM 42.39.704(3) before resuming delivery operations

Notes

Montana's delivery endorsement framework is relatively straightforward; most violations stem from operators who begin delivering before completing the endorsement paperwork. Operators should confirm endorsement status in writing with the Division before initiating delivery.