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DEA’s New/Old View on Due Diligence Requirements

By Larry P. Cote on September 30, 2020
Posted in DEA Compliance, DEA Final Orders, Due Diligence, Enforcement Actions

On September 30, 2020, DEA published a Final Rule (FR) adopting the Interim Final Rule (IFR) implementing the Ryan Haight Act. The FR made a few technical changes to the regulations and did not substantively change the IFR. What garnered my attention was DEA’s response to comments submitted after publication of the IFR.

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