Enforcement Summaries
Investigative and Enforcement Services’ (IES) Enforcement Summaries provide a summary of the enforcement actions APHIS has taken to help promote compliance with APHIS-administered laws. It is important to recognize that these enforcement actions are just one tool APHIS uses to promote compliance, and this tool is only one aspect of the Agency’s mission to protect the health and value of American agriculture.
APHIS has several available options to resolve a case in which the evidence substantiates that an alleged violation has occurred. These options include issuing regulatory correspondence (such as an official warning) to the individuals or businesses involved in the alleged violation; offering to resolve the case through a stipulated penalty; and referring the case to the USDA Office of the General Counsel for formal administrative action before the USDA Office of Administrative Law Judges or referral to the U.S. Department of Justice. The Enforcement Actions tabs below describe the various types of enforcement actions APHIS took during fiscal year 2025 and show the distribution of those enforcement actions among the APHIS programs.
Enforcement Actions and Regulatory Correspondence
APHIS Investigative and Enforcement Services’ open inventory of cases involve investigative, enforcement, and regulatory support services for the four APHIS programs it serves, as well as for agricultural quarantine inspection activities carried out by the Department of Homeland Security’s Customs and Border Protection. A case may involve one or more individuals or businesses.
In fiscal year 2025, APHIS Investigative and Enforcement Services opened 1,269 new cases; issued 818 warning letters; entered into 487 pre-litigation settlement agreements resulting in the collection of $869,947 in stipulated penalties; and obtained, through Office of the General Counsel action, Administrative Orders assessing $257,269 in civil penalties.
APHIS Investigative and Enforcement Services cases involve investigative, enforcement, and regulatory support services for the four APHIS programs it serves, as well as for agricultural quarantine inspection activities carried out by the Department of Homeland Security’s Customs and Border Protection.
Each case is different and may vary in investigative scope, complexity, and time required to review. Some cases may involve multiple individuals or organizations, traverse multiple states and/or U.S. territories, and include multiple alleged violations—any of which might require extensive investigative resources to obtain sufficient evidence to determine whether an alleged violation has occurred. Other cases may be more straightforward, where the initial evidence clearly substantiates the alleged violation, allowing Investigative and Enforcement Services to more quickly process the case to help APHIS officials determine the appropriate resolution. Finally, Investigative and Enforcement Services conducts a streamlined review of certain cases involving agricultural quarantine inspection activities, such as alleged regulated garbage and passenger baggage violations. These cases are completed as part of an expedited resolution program, in which Customs and Border Protection refers a case to APHIS while simultaneously providing evidence related to the alleged violation.
In fiscal year 2025, Investigative and Enforcement Services opened a total of 1,269 new cases in support of the four APHIS programs and Customs and Border Protection. The distribution of these cases is shown in the following chart, categorized by program area.
At the end of fiscal year 2025, Investigative and Enforcement Services had 316 open cases at various stages of the investigation and enforcement process. Distribution of those cases is shown in the following chart, organized by program.
In fiscal year 2025, APHIS Investigative and Enforcement Services issued 818 official warnings to individuals or businesses involved in cases in which the evidence substantiated that an alleged violation of an APHIS-administered statute or regulation occurred, but for which APHIS chose not to pursue a civil penalty or formal administrative action. An official warning or other regulatory correspondence is not a penalty, nor is it an enforcement action against an individual or business. Rather, the purpose of official warnings and other regulatory correspondence is to provide notice of the legal requirements and information to promote compliance with the law. Distribution of warning letters is shown in the following chart, categorized by program area.
In many instances, APHIS may enter into a settlement agreement (or stipulation) to resolve alleged violations of APHIS-administered laws. In cases where the evidence substantiates that a violation occurred, and the circumstances of the alleged violation are such that APHIS determines that a penalty is appropriate, Investigative and Enforcement Services may offer to resolve the case through these pre-litigation settlement agreements.
In fiscal year 2025, APHIS Investigative and Enforcement Services issued 487 pre-litigation settlement agreements, resulting in the collection of $869,947 in stipulated penalties. The distribution of all cases where APHIS resolved the case with pre-litigation settlement agreements are shown in the following two charts.
For cases involving serious violations or for which regulatory correspondence or a pre-litigation settlement agreement may not be appropriate, APHIS Investigative and Enforcement Services may refer the case to USDA’s Office of the General Counsel to initiate formal administrative action before the USDA Office of Administrative Law Judges and to seek civil penalties or other sanctions for alleged violations of APHIS statutes.
APHIS has many cases in various stages of the formal administrative process before the Office of Administrative Law Judges, including several under judicial review, in coordination with the Office of the General Counsel. Formal administrative action usually begins by filing an administrative complaint against a respondent. At that time, the USDA Hearing Clerk will assign a “docket number,” which is a unique number assigned to an administrative complaint. A single respondent may have more than one pending administrative complaint.
In fiscal year 2025, APHIS, through the Office of the General Counsel, obtained decisions and orders in 22 proceedings assessing $257,269 in civil penalties. The decisions and orders included orders suspending or revoking 3 Animal Welfare Act licenses and disqualifying 10 individuals from participating in activities regulated under the Horse Protection Act.
IES Activity by Program Area
To support AQI animal and plant health activities in fiscal year 2025, APHIS Investigative and Enforcement Services initiated 877 cases, issued 297 official warnings, issued 468 pre-litigation settlement agreements, resulting in the collection of $791,422 in stipulated penalties, and obtained three administrative orders resulting in the assessment of $22,589 in civil penalties.
In 2025, for example, Investigative and Enforcement Services negotiated a pre-litigation settlement of $150,000 involving importing seeds without required permits and phytosanitary certificates. In another case, working with OGC, Investigative and Enforcement Services obtained a Consent Decision and Order assessing a penalty of $20,000 for the release of shipments of cut flowers in violation of agricultural inspection hold orders placed by Customs and Border Protection.
To support animal welfare in fiscal year 2025, APHIS Investigative and Enforcement Services initiated 240 cases for alleged violations of the Animal Welfare Act (AWA), issued 275 official warnings, obtained 8 administrative orders resulting in the assessment of $5,500 in civil penalties, and suspended or revoked 3 licenses.
For example, Investigative and Enforcement Services negotiated a non-monetary pre-litigation settlement revoking the license of an exhibitor. In another case, working with OGC, Investigative and Enforcement Services obtained a Consent Decision and Order directing a breeder to cease and desist from violating the Animal Welfare Act and assessing a penalty of $1,000.
To support horse protection in fiscal year 2025, APHIS obtained 10 administrative orders resulting in the assessment of $19,180 in civil penalties and the disqualification of 10 individuals from participating in activities regulated under the Horse Protection Act.
In one case, working with OGC, Investigative and Enforcement Services obtained a Consent Decision and Order assessing a penalty of $4,000 and a two-year disqualification period for entering a sore horse at a show in Kentucky.
APHIS Investigative and Enforcement Services has continued to post copies of enforcement records (such as initial decision and orders, default decisions, consent decisions, and administrative complaints) on its website at Animal Welfare and Horse Protection Actions.
To support biotechnology regulation in fiscal year 2025, APHIS Investigative and Enforcement Services issued one official warning related to alleged violations of permit conditions for genetically modified soybeans.
To support plant health in fiscal year 2025, APHIS Investigative and Enforcement Services initiated 26 cases, issued 22 official warnings, and negotiated 6 pre-litigation settlement agreements resulting in the collection of $65,775 in stipulated penalties.
In one case, Investigative and Enforcement Services negotiated a pre-litigation settlement of $35,000 for the importation of prohibited fruit from Argentina.
To support animal health, in fiscal year 2025, APHIS Investigative and Enforcement Services initiated 126 cases, issued 223 official warnings, issued 12 pre-litigation settlements resulting in the collection of $12,750 in stipulated penalties, and obtained one administrative order assessing $210,000 in civil penalties.
For example, Investigative and Enforcement Services negotiated a prelitigation settlement in the amount of $3,250 to resolve violations involving moving cattle interstate without proper health certificates. In another case, working with USDA’s Office of General Counsel (OGC), Investigative and Enforcement Services prevailed on appeal of a Decision and Order assessing a penalty of $210,000 for moving horses interstate without proper documentation and with potential to spread equine infectious anemia.