Published Investigation
Sample Investigation: Unauthorized ENDS Distributor Network
Multi-state distribution network operating without authorization
Executive Summary
This investigation documents a multi-state distribution network operating without PMTA authorization, PACT Act registration, or state-level licensing. Shell company structures were identified across three jurisdictions, with overlapping corporate officers and shared digital infrastructure.
Entity Overview
The subject entity operates under multiple DBAs across Texas, California, and Florida, distributing unauthorized ENDS products through both wholesale and direct-to-consumer channels.
Key Findings
- No PMTA Authorization — None of the distributed products appear in the FDA PMTA authorization database.
- PACT Act Non-Compliance — No registration found in the ATF PACT Act registry for any associated entity.
- Shell Company Structure — Three LLCs share a registered agent, mailing address, and beneficial owner across three states.
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