How We Built the First Two Adult-Use Cannabis Operations in Washington DC

When Washington DC legalized adult-use cannabis, there was no precedent. No other jurisdiction had done exactly what DC was doing — a framework being written in real time by a regulatory body that had never overseen adult-use cannabis before. The rules that would govern licensing, compliance, and operations were being finalized while applications were being accepted.

Our Managing Principal led the licensing strategy and compliance buildout for the first two adult-use cannabis operations in DC. This is the story of what we built, what we learned, and what operators entering new markets — including Virginia in 2027 — can take from the DC experience.

The DC Context — What Made It Different

DC's adult-use cannabis framework emerged from Initiative 71, passed by voters in 2014, which legalized personal possession and home cultivation but left the commercial licensing framework to the DC Council. The regulatory framework that eventually emerged — governed by the Alcoholic Beverage and Cannabis Administration — was being actively drafted while the first applications were being considered.

This created a challenge that most operators never face: how do you build a compliant operation when the compliance standards are still being written? How do you prepare an application when the scoring criteria are not fully published? How do you design a facility when the security requirements are still in comment period?

The answer is that you build relationships with the regulatory body before you file, you build flexibility into every design decision, and you staff with people who have done this before in other jurisdictions where the regulatory frameworks were also being built from scratch.

What We Built

The Licensing Strategy

The core of a first-mover licensing strategy in a new market is not just preparing the best application — it is shaping the process while the process is being built. Joy Langley's government affairs background was directly relevant here: understanding how regulatory agencies actually work, who the decision-makers are, what they worry about, and how to engage them constructively before the application window opens is a different skill set than application drafting.

We engaged with ABCA staff during the public comment period on the draft regulations. We participated in community meetings in the target neighborhoods. We built community relationships before we filed. When the applications were reviewed, the reviewers were not evaluating an unknown applicant — they were evaluating operators they had already seen show up and engage.

The Compliance Buildout

Jenny Wyne built the complete opening program for District Cannabis — the SOPs, compliance documentation, staff training, and onboarding system. Building a compliance program for a first-of-kind operation in a new market is different from adapting existing programs to a new jurisdiction. There was no template. Everything was built from first principles, informed by Jenny's experience opening dispensaries in markets where compliance programs had been refined over years.

• Complete SOP library — 47 operating procedures covering every aspect of retail operations
• METRC seed-to-sale integration — DC uses METRC; every workflow was built around METRC compliance
• Staff training program — built for a team that had never worked in a licensed cannabis environment before
• Compliance audit program — internal audit schedule and checklist library
• Inspection readiness protocol — what to do when a regulator walks in

Opening Day and the First Year

Both operations opened on schedule, fully staffed, and fully compliant. ABCA conducted its first compliance inspection within 60 days of opening — standard for new licensees. The inspections found zero deficiencies across both operations.

The compliance program Jenny built was not designed to look good on paper — it was designed to survive real-world operations and real-world inspections. That distinction matters more than most operators realize until they have been through their first inspection.

What Virginia Operators Can Take From the DC Experience

Virginia's 2027 licensing window is not exactly like DC's first-mover experience — Virginia has an existing medical cannabis framework, a more developed regulatory body, and a clearer set of rules. But several lessons from DC apply directly:

• Relationship before application. The operators who engage with the Virginia CCA during the comment and planning periods before September will be viewed differently than operators who appear only at application time.
• Community before license. Virginia's scoring framework rewards community integration. Operators who have existing community relationships when they apply score better than operators who announce their community intentions in the application.
• Compliance infrastructure, not compliance paperwork. The SOPs in your application need to reflect how your operation will actually run — not what reviewers want to see on paper.
• Staff certification is a hard requirement. In DC, we trained every staff member before opening day. Virginia requires certification. Do not open without it.