As someone who works with both the alcohol and cannabis industries, with a volunteer stint as a first responder, I must recognize the leadership and cooperation demonstrated the past couple weeks from the California Department of Alcoholic Beverage Control (the “ABC”). ABC has not only interacted directly with stakeholder attorneys to efficiently and anonymously consider industry questions and ideas for regulatory relief, but they have taken immediate and meaningful actions to address regulatory restrictions that may stress or harm this important industry (read our previous posts here, here, here and my take on quickly executing promotions here). They have even reversed some of their own relief actions when their initial response didn’t go far enough (see ABC’s second notice of regulatory relief here).

On March 25, 2020, the ABC updated the Frequently Asked Questions (“FAQs”) posted on its website, https://www.abc.ca.gov/law-and-policy/coronavirus19/frequently-asked-questions/, to guide licensees dealing with the evolving COVID 19 crisis. The ABC, while it does provide meaningful relief from many onerous regulations, by no means is foregoing its responsibility as a law enforcement agency. Rather, licensees must be cognizant of the limited scope (both temporal and substantive) of the regulatory relief.