This month marks the one-year anniversary of former Governor Andrew Cuomo signing the Marihuana Regulation and Taxation Act (MRTA) into law. Yet, a year on, it does not appear that proposed regulations—and licenses—for commercial adult-use cannabis market are on the near horizon. This likely means that sales under the MRTA will not begin in earnest until the first quarter of 2023, at the earliest.

However, it does appear that New York is poised to issue some conditional licenses this year as part of its “Seeding Opportunity Initiative,” which seeks to prioritize individuals impacted by the war on drugs as part of the licensing process. In order to create the infrastructure for some limited sales in 2022, the initiative has three prongs.

The Conditional Adult-Use Retail Dispensary License

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