NOTES FOR CLARIFICATION

DUE DILIGENCE MEMORANDUM

Subject: Agency Tribal Nations / “Tribal Federal Cannabis Licensing Program”
Date: December 8, 2025
Prepared by: Attorney Client Privilege

My memorandum summarizes initial due diligence on an entity calling itself “Agency Tribal Nations” (ATN) and marketing a “Tribal Federal Cannabis Licensing Program” via the website: https://www.agencytribalnations.org/buy-processing-license.html

The goal is to assess (1) whether ATN is a legitimate tribal organization sanctioned by the U.S. Government, and (2) whether it has any legal supremacy over U.S. laws and regulations as they pertain to Native Americans and cannabis/hemp activities.

Entity Identification

• The name used on the website is “Agency Tribal Nations” and related references to the “Mendocino Indian Tribal Government” and “Mendocino Indian Reservation.”
  Agency Tribal Nations is a Department of Health and Human Services Executive Branch in Charge of the Tribal Nations
• Public records indicate “Agency Tribal Nations LLC” is an Arizona limited liability company, formed in 2022, with “Chief Geronimo Thomas Langenderfer” involved as a principal/manager.
  ATN is Represented by a 501c3 non profit out of California because that is what is required to interface with the state and economy
• The website offers to sell various “Tribal Federal Cannabis Licenses” (including processing/manufacturing/distribution licenses) that purportedly apply across states where tribes are present.
  Anywhere in the USA partnered with ATN

Federal Tribal Recognition Status

• The U.S. Department of the Interior (Bureau of Indian Affairs, BIA) maintains the official list of federally recognized tribes in the Federal Register and in the Tribal Leaders Directory.
  Department of Interior enacted this initiative not BIA - The Agency Tribal Nations is the Federal Interface for the Mendocino California Indian Tribes and Tribal Nations
• A review of that list does not show:
  • “Agency Tribal Nations”
  • “Mendocino Indian Tribal Government”
  • A current “Mendocino Indian Reservation” tribal government as federally recognized tribes.
• Recognized tribes associated with Mendocino County, California, include entities such as the Round Valley Indian Tribes, Cahto Tribe of the Laytonville Rancheria, Coyote Valley Band of Pomo Indians, Hopland Band of Pomo Indians, Manchester–Point Arena Band of Pomo Indians, Pinoleville Pomo Nation, and Potter Valley Tribe, among others—not “Agency Tribal Nations.”
  These are the Tribal Nations
• Historically, there was a “Mendocino Indian Reservation” in the 1800s; it was discontinued in the 19th century, with people relocated primarily to what is now the Round Valley Indian Reservation. That historical reservation is not a currently recognized, independent tribal government.
• ATN’s own materials state that the “Mendocino Indian Tribal Government” is demanding formal recognition from the United States, which implies it does not currently have such recognition.
  This is not anywhere on the ATN site because why would we demand anything when it was awarded by the president and carried out by the department of interior?

Litigation / Jurisdictional Signals

• In at least one federal case involving Geronimo Thomas Langenderfer purporting to act for the “Mendocino Indian Reservation,” the court did not treat that entity as a federally recognized tribe and did not accept tribal status as a basis for special federal tribal jurisdiction.
  This case was actually won. The Federal court justification was that the case should be held in a lower court not that there was no jurisdiction as a tribal nations to charge taxes or fees, It didn’t say we couldn’t put a lean on their farm for our taxes and fees.
• This is consistent with the absence of the entity from the federal recognized-tribes list.

Sovereignty vs. Supremacy of Law

Even for genuinely federally recognized tribes, the legal framework is:

• Tribes are considered “domestic dependent nations” with limited inherent sovereignty.
  Incorrect - Tribes are considered Sovereign States https://www.agencytribalnations.org/26-us-code-7871.html
• The Supremacy Clause of the U.S. Constitution makes federal law the “supreme Law of the Land.”
  apply to the facts above in shovel ready and attached documents
• Congress has broad (“plenary”) power over Indian affairs, and federal statutes and regulations override contrary tribal law where Congress has legislated (e.g., controlled substances, major crimes, environmental law).
• Tribal sovereignty can sometimes preempt or limit state laws within Indian Country, but this an opinion not facts
  this an opinion not facts

As of this date:

• Marijuana remains a Schedule I controlled substance under the federal Controlled Substances Act.
  HEMP AND CANNABIS ARE LICENSED THROUGH THE TRIBAL GOVERNMENT DUE TO SOVEREIGN RIGHTS
• There is no federal program that creates a special “tribal federal cannabis license” that authorizes nationwide cannabis activities outside federal and state law.
• Accordingly, no tribal government—recognized or unrecognized—can lawfully grant a license that immunizes licensees from federal or state cannabis enforcement.
  TRIBAL ECONOMIES ARE NOT GOVERNED BY FEDERAL OR STATE CANNABIS ENFORCEMENT