Suspicious Order Reports

Just when you thought it was safe to have a robust order monitoring program to detect and report suspicious orders, DEA has moved the goal post.  In previous posts (here and here), we’ve talked about DEA’s “extra-regulatory” guidance on both suspicious orders and “due diligence”.  In late February-early March, the DEA held a

…to infinity and beyond! For years manufacturers and distributors have searched for the holy grail of DEA compliance – specific guidance from DEA on what actually constitutes a suspicious order.  The obvious source of assistance and the sole legal basis establishing the requirement to detect and report suspicious orders is found in DEA’s own regulations.