On May 26, 2023, the Drug Enforcement Administration (DEA) published a final decision and order (the “Final Order”) affirming an Administrative Law Judge's (ALJ) August 29, 2019 recommendation (the “ALJ Order”) to revoke DEA registrations held by the United States’ fourth largest wholesale drug distributor — Morris & Dickson Co., LLC (“Morris & Dickson”). See 88 FR 34523 (DEA Docket No. 18-31). Remarkably, the Final Order comes over five (5) years since DEA first issued the underlying May 2, 2018 Order to Show Cause (“OSC”) and Immediate Suspension of Registration (“ISO”). DEA’s 68-page Final Order concentrated on Morris & Dickson’s distribution of oxycodone and hydrocodone from 2014-2018. During this four-year period, DEA found that the wholesaler failed to design and operate a suspicious order monitoring system (“SOM System”), it failed to investigate or report suspicious orders to DEA as required by 21 CFR 1301.74(b), and it failed to maintain effective controls against diversion by distributing controlled substances without performing adequate customer due diligence. Specifically, DEA referenced 12,000 “unusually large” and potentially reportable oxycodone and hydrocodone orders that Morris & Dickson fulfilled during those four years, yet it only reported three orders as suspicious during that time.The Final Decision only briefly discussed Morris & Dickson’s remedial m