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Man’s Best Fraud

When I think of a beagle, the image of Snoopy lying on top of his doghouse in the Peanuts cartoon comes to mind. Perhaps Snoopy was dressed as a fighter pilot and was fighting the dastardly Red Baron. Either way, the beagle dog is a cute, friendly, fun loving companion. Further, beagles are used today as part of the Beagle Brigade, trained and assigned to various terminals at airports to help sniff out agricultural threats from foreign food and plants in luggage on U.S. arriving flights. Man's Best Fraud by Kevin Sullivan, CAMS President of The AML Training Academy and Advisory - Beagle Brigade Unfortunately, beagles are the most common dog breed used in medical testing due to their docile nature. For the last few years thousands of beagles were bred, specifically for sale to medical laboratories, at a massive breeding facility, Envigo RMS in Virginia. Envigo RMS is a leading supplier of animals for medical research and experimentation in the United States. At one point Envigo housed over 5000 beagles. Inotiv, the parent company who purchased Envigo RMS in 2021, states on their website, “We support our clients from the beginning of discovery, through investigational new drug (IND) and beyond.” Inotiv clients include major pharmaceutical companies, universities and the federal government. Unfortunately, the conditions that these beagle’s were kept was horrific. Envigo RMS failed to provide adequate veterinary care, there was a lack of appropriate staffing and the living conditions for the dogs was deplorable. As if that was not cruel enough, it was discovered that these dogs and puppies were kept in conditions and treated in ways that any reasonable person would find reprehensible. As a huge dog lover myself, reading about the violations was cringe worthy. A few of the violations were: a lack of veterinary care with only one Vet for 5000 dogs, unsanitary conditions, euthanizing dogs without anesthesia, under-feeding mothers nursing puppies, failing to document the cause of death for hundreds of puppies, and dogs housed in crowded and filthy living conditions.

Snoopy Strikes Back

Man's Best Fraud by Kevin Sullivan, CAMS Presidrent of The AML Training Academy and Advisory

Judicial decisions, all bark and no bite.

Fortunately, over 4000 beagles were rescued in 2022 from this hell hole and have been distributed to numerous animal shelters around the country. Recently there was a little beagle revenge! As of June 3, 2024, Envigo RMS was fined $35 million by the Department of Justice (DOJ). Additionally, Inotiv has agreed not to breed dogs for five years. The breakdown of the fine was $22 million to the US Government, $1.1 million to the Virginia Animal Fighting Task Force, $1.9 to the Humane Society of the U.S., $3.5 million to National Fish & Wildlife Foundation, and, get this, $7 million to update their facilities! What! So some of the penalty money goes right back to them to fix up the joint. That’s like giving a crackhead a job at the pharmacy after he promises to sweep up. I hope if I ever get a speeding ticket I can get some of the fine money back so I can get a new set of tires. Here’s a suggestion: How about some of the fine money go to a fund to assist with future medical bills for these dogs? After all, you are asking the general public to adopt these dogs out of the kindness of their hearts but aren’t accounting for the potential expense of doggie healthcare that these poor animals may require as a result of the horrible experience they endured.

So, as I type away with my very spoiled German Shepherd’s laying at my feet, my very suspicious investigative mind is churning. The DOJ said that Envigo RMS prioritized profits over following the law, which resulted in dire consequences. Doesn’t this sound remotely familiar to various financial institution scandals? It sounds even more like a financial institution with regulatory levees against them as no one ever seems to get handcuffed or go to jail. Considering that most crimes are committed for the purpose of profit, it makes me wonder if the DOJ is following the money trail here? We have the predicate crime of a violation of the Animal Welfare Act. What was the source of funds? Supposedly funds came from various experimental laboratories. Just what laboratories? Sponsored by what company or division of government? Who profited from this? Is there more here than meets the eye? Drug cartel’s have been known to use livestock and dogs to smuggle drugs into the country. I will spare you the gory details.  During any investigation I always had the feeling of “What am I missing?” So, is that possible here also? In my opinion, there is more work for the good guys to do here. A bit of beagling to stay on the trail, hunt down, and flush out the answers to some of these questions. Reportedly, as part of the court order, besides a fine, Envigo RMS (Inotiv) will be subject to a compliance monitor. I’m not really sure who selects the monitor or what the particular qualifications are for a monitor in this situation. Is it similar to a monitor for a financial institution’s Deferred Prosecution Agreement? Oh please, may the wisdom of the K9 gods kindly look down and select me for this job! 

    Snoopy to the Rescue

    A bipartisan measure has been introduced by Senator’s Kennedy and Blumenthal and also Representatives Reschenthaler and Quigley.  This is called The Better Care for Animals Act.  

    The Better CARE for Animals Act would:

    • Man's Best Fraud by Kevin Sullivan, CAMS President of The AML Training Academy and Advisory

      The Better Care for Animals Act

      Strengthen the Department of Justice’s (DOJ) ability to enforce the Animal Welfare Act by clarifying that the DOJ has the same authority that the U.S. Department of Agriculture wields under the Animal Welfare Act, including the ability to seek license suspensions, revocations and civil penalties.
    • Expand on the Animal Welfare Act by granting the DOJ forfeiture authority to seize and remove animals experiencing harmful treatment.

    I hope that our leaders can get behind this and have more compassion for our furry friends.  Now I’m going to play fetch with my Shepherd’s and try to erase all the images of Envigo running through my brain. “Come on boys…let’s go outside!

      I work with AML/BSA/AFC/CTF compliance programs large and small, if you need a customized and quality anti-money laundering program, training, or advise I invite you to contact me to learn how I can help with your compliance needs.

      Kevin Sullivan, CAMS, CCI

      President of The AML Training Academy and Advisory LLC

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      About the Author

      Kevin Sullivan, CAMS, CCI is a retired New York State Police Investigator and Federal Agent who dedicated his career to AML and continues that work through his company, The AML Training Academy and Advisory LLC. Kevin coordinated AML investigations for the state of New York while being detailed to one of the worlds largest AML task forces, the NY High Intensity Financial Crime Area (HIFCA) El Dorado Task Force. He has helped develop and implement global AML guidelines and trained and advised all industries and government agencies requiring AML around the globe. He helped to write various certification programs for the Association of Certified Anti-Money Laundering Specialists’ (ACAMS) and was the co-founder and former chair of their inaugural chapter which was in NY. Follow Kevin or reserve a seat in one of his live webinars. Space is limited!

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