Ryan Kocot is a New York cannabis attorney that represents cannabis businesses operating in or entering the New York adult-use and medical marijuana markets. We advise operators on Office of Cannabis Management (OCM) licensing, Cannabis Control Board (CCB) compliance, and the unique features of New York’s regulatory framework — including the social and economic equity priorities that shaped the rollout and the True Party of Interest restrictions that continue to trip up applicants.

Ryan Kocot is admitted to practice in New York. Our New York practice serves operators who need experienced cannabis counsel familiar with both East Coast and West Coast market dynamics.

New York adult-use cannabis is governed by the Marijuana Regulation and Taxation Act (MRTA), enacted in 2021 and codified primarily at Cannabis Law Article 4. The Office of Cannabis Management implements and enforces the MRTA under the direction of the Cannabis Control Board, with operating regulations at 9 NYCRR Part 116 and related parts.

New York’s structure differs meaningfully from most legal-state frameworks:

• Two-tier (mostly). The MRTA prohibits vertical integration with limited exceptions for microbusinesses and registered organizations transitioning from medical. Cultivators generally cannot also distribute or retail.

• Equity-forward licensing. The MRTA targets 50% of licenses to social and economic equity applicants. The Conditional Adult-Use Retail Dispensary (CAURD) program prioritized justice-involved individuals as the first wave of retail licensees.

• True Party of Interest (TPI) rules. OCM regulations impose strict ownership and control disclosures. Passive investors, management companies, brand licensors, and supplier relationships can all trigger TPI status. Misclassification is one of the most common and most consequential application errors in New York cannabis.

• Limited municipal control. Unlike California, New York municipalities could only opt out of retail and on-site consumption, and only by year-end 2021. Cultivation, processing, and distribution facilities are not subject to municipal opt-out.

• Cultivator (Indoor, Outdoor, Combination, Mixed-Use)
• Processor
• Distributor
• Retail Dispensary (including CAURD)
• Microbusiness
• On-Site Consumption
• Delivery
• Registered Organization (medical)

DEA REGISTRATION FOR NEW YORK MEDICAL CANNABIS BUSINESSES

Following the April 2026 rescheduling, New York medical operators (registered organizations) are now eligible for DEA registration under 21 C.F.R. § 1301.13(k). We prepare federal registration applications and Federal Status Change advisories for New York medical operators, including the public-interest analysis required under 21 U.S.C. § 823(e).

We prepare and file OCM license applications, including operating plans, security and compliance protocols, social and economic equity submissions, and TPI disclosures. We also handle license amendments, location changes, and ownership modifications under 9 NYCRR Part 116

Compliance and Enforcement Defense

• OCM inspection responses and corrective action plans
• Advertising and marketing review
• Recordkeeping, security, and inventory compliance audit

• Entity structuring compliant with TPI restrictions
• Management services agreements that survive OCM scrutiny
• Investment documentation for passive equity, including convertible instruments and revenue-share arrangements
• Acquisition and sale of New York cannabis licenses
• Brand licensing and intellectual property arrangements that respect cross-tier prohibitions