Federal Agencies Ordered to Prioritize Animal Welfare Enforcement, Elevating Compliance Risks for Regulated Organizations

Entities regulated by the Animal Welfare Act (AWA) are potentially facing an unprecedented wave of federal enforcement as DOJ, USDA, HHS, and DHS unleash a plan to intensify inspections, increase compliance demands, and coordinate enforcement efforts like never before — making proactive preparation essential for all affected organizations.

Attorney General Pam Bondi, Agriculture Secretary Brooke L. Rollins, former Homeland Security Secretary Kristi Noem, and HHS Secretary Robert F. Kennedy, Jr. jointly declared their departments’ historic commitment to holding animal welfare violators accountable and strengthening overall enforcement and oversight.

This historic multi-agency announcement initially appears to focus on a “crackdown” on chronic violators of federal animal welfare laws involving the breeding, import, and sales of dogs only. However, as evidenced by DOJ’s simultaneously announced plan, this initiative covers a more expansive range of animals, including those exhibited at zoos or imported into the country for other uses.

Bondi ordered DOJ to prioritize its nationwide enforcement of the AWA by coordinating consistent prosecution strategies among key agencies, including DOJ’s Environment and Natural Resources Division (ENRD), USDA, the FBI, the U.S. Marshals Service, and the U.S. Immigration and Customs Enforcement’s Homeland Security Investigations branch. DOJ’s plan “to combat animal welfare crimes” as detailed in Bondi’s memorandum includes (1) national training for prosecutors; (2) a new interagency strategic committee headed by ENRD’s Principal Deputy Assistant Attorney General, Adam Gustafson; (3) a dedicated law enforcement “Tiger Team” for AWA cases; (4) a forfeiture fund to support care for seized animals; and (5) anti-cruelty grants. These measures reflect a significant escalation in federal coordination and resources to address and prevent animal welfare violations.^[1]

Animal Testing is Also in the Crosshairs. Bondi, Rollins, and Kennedy also jointly emphasized coordinating actions across their agencies to target not only dog fighting and puppy mills, but also animal testing, in a joint interview in December 2025, the day after 20 members of Congress issued a letter to the National Institutes of Health concerning animal testing practices. In April 2025, the FDA outlined its “Roadmap to Reducing Animal Testing in Preclinical Safety Studies,” citing limitations and ethical concerns as a basis for implementing new approach methodologies. In January 2026, the EPA also announced its goal of similarly phasing out animal testing by 2035. Although animal research remains essential for specific scientific studies and cannot yet be fully replaced by alternative methods, the administration’s initiative is likely to subject such practices to heightened scrutiny.

Recent Enforcement Actions Signal the Initiative Is Already Underway. Following the administration’s announcement, DOJ filed a civil complaint in the U.S. District Court for the Eastern District of Michigan against K&M Pets, a licensed animal dealer, for repeated AWA violations, including denial of inspection access and fraudulent recordkeeping. On February 27, 2026, DOJ secured a temporary restraining court order effectively prohibiting K&M Pets from engaging in any AWA-regulated activity and permitting immediate, unannounced federal inspection access.

What to Expect. This unprecedented enforcement push is not limited to dogs. The AWA and related statutes cover a much broader range of animals and activities, and investigations can expand to cover multiple statutes, resulting in multimillion-dollar penalties and restitution for environmental harm. Agencies are also likely to shift focus toward facility inspections across a wider range of animal-related operations. Facility inspections are arguably faster at uncovering AWA violations than investigating illegal dog fighting operations, which can be dangerous and difficult to uncover.

For example, the 2024 criminal prosecution of a dog-breeding facility resulted in a $35 million fine for AWA violations, plus Clean Water Act penalties for unlawful discharges of untreated wastewater. See US v. Envigo RMS LLC, et al, No. 6:24-cr-00016 (W.D. Va).

Steps to Take Now. Potentially impacted businesses should take the following steps to ensure that their operations fully comply with the AWA and its regulations and that they are prepared for inspections or other enforcement activity:

• Schedule proactive compliance audits with a focus on foreign suppliers.
• Train frontline employees on effective communication and strategies to minimize mistakes during agency inspections and ensure they are prepared to handle unannounced visits proactively.
• Maintain organized, transparent, and accurate documentation involving chain of custody and disposition of animals, veterinary oversight, training records, incident reporting, quarantine protocols, customs permitting, and seller and broker licensing compliance.
• Monitor enforcement updates, guidance materials, and rulemaking from USDA and closely related agencies, including U.S. Fish and Wildlife Service and EPA.
• Develop crisis response procedures for inspections (whether noticed or unannounced), violation citations or notices, animal seizures, public complaints, or major incidents — while reviewing legal strategy and media response.

Conclusion

The Trump administration is channeling its full federal enforcement energy into animal welfare. While the top federal agencies mobilize their coordinated enforcement initiative, impacted entities should consider proactively assessing and strengthening their compliance protocols while time allows — and be prepared to respond quickly and proactively to any enforcement activity. Crowell & Moring will continue to monitor enforcement trends.