If you are looking into , The "Membership" Business Model
: Their legal team has argued that because there is no direct "transfer for compensation" for the cannabis itself, the business operates within the "gifting" or "sharing" provisions of the Marijuana Regulation and Taxation Act (MRTA). Legal Enforcement and Raids empirecannabisclub
The state’s Office of Cannabis Management (OCM) has repeatedly rejected this logic, viewing it as an unlicensed sale of cannabis. If you are looking into , The "Membership"
Empire Cannabis Club operates as a private, nonprofit concierge service. This model was designed to navigate New York's early cannabis laws by claiming that they do not "sell" marijuana, but rather provide it as a benefit of a paid membership. This model was designed to navigate New York's
As of early 2026, the status of individual locations is mixed, with some marked as permanently closed following state enforcement. Manhattan Cannabis Chain Raided by Police and State Agents
: The club claims it merely facilitates the acquisition of cannabis on behalf of its members, rather than acting as a traditional retailer.
: Empire was among the first businesses to receive "cease and desist" letters in 2022, which the owners largely ignored to continue operations.