On August 25, 2022, the Drug Enforcement Administration (DEA or Government) issued an Order to Show Cause (OSC) to Syed Warsi, M.D., of North Aurora, Illinois (Registrant). Request for Final Agency Action (RFAA), Appendix (RFAAX) A, at 1, 3. The OSC proposed the revocation of Registrant's Certificate of Registration No. BW8048022, alleging that Registrant's registration should be revoked because Registrant is “currently without authority to prescribe, administer, dispense, or otherwise handle controlled substances in Illinois, the jurisdiction in which [he is] registered with DEA.” Id. at 2 (citing 21 U.S.C. 824(a)(3)).^[1]

The Agency makes the following findings of fact based on the uncontroverted evidence submitted by the Government in its RFAA dated October 12, 2023.^[2]

Findings of Fact

On July 13, 2022, the Illinois Department of Financial and Professional Regulation suspended Registrant's Illinois medical license and Illinois controlled substance license. RFAAX C, at 4-5. According to Illinois's online records, of which the Agency takes official notice, Registrant's Illinois medical license and Illinois controlled substance license both remain suspended.^[3] Illinois Department of Financial and Professional Regulation License Search, https://online-dfpr.micropact.com/​lookup/​licenselookup.aspx/​ (last visited date of signature of this Order). Accordingly, the Agency finds that Registrant is not licensed to practice medicine nor to handle controlled substances in Illinois, the state in which he is registered with DEA.^[4]

Discussion

Pursuant to 21 U.S.C. 824(a)(3), the Attorney General is authorized to ( printed page 17455) suspend or revoke a registration issued under 21 U.S.C. 823 “upon a finding that the registrant . . . has had his State license or registration suspended . . . [or] revoked . . . by competent State authority and is no longer authorized by State law to engage in the . . . dispensing of controlled substances.” With respect to a practitioner, DEA has also long held that the possession of authority to dispense controlled substances under the laws of the state in which a practitioner engages in professional practice is a fundamental condition for obtaining and maintaining a practitioner's registration. Gonzales v. Oregon, 546 U.S. 243, 270 (2006) (“The Attorney General can register a physician to dispense controlled substances `if the applicant is authorized to dispense . . . controlled substances under the laws of the State in which he practices.' . . . The very definition of a `practitioner' eligible to prescribe includes physicians `licensed, registered, or otherwise permitted, by the United States or the jurisdiction in which he practices' to dispense controlled substances. § 802(21).”). The Agency has applied these principles consistently. See, e.g., James L. Hooper, M.D.,76 FR 71371, 71372 (2011), pet. for rev. denied, 481 F. App'x 826 (4th Cir. 2012); Frederick Marsh Blanton, M.D.,43 FR 27616, 27617 (1978).^[5]

Pursuant to the Illinois Controlled Substances Act, a “practitioner” means “a physician licensed to practice medicine in all its branches . . . or other person licensed, registered, or otherwise lawfully permitted by the United States or this State to distribute, dispense, conduct research with respect to, administer or use in teaching or chemical analysis, a controlled substance in the course of professional practice or research.” 720 Ill. Comp. Stat. 570/102(kk) (2024). Further, the Illinois Controlled Substances Act requires that “[e]very person who manufactures, distributes, or dispenses any controlled substances . . . must obtain a registration issued by the Department of Financial and Professional Regulation in accordance with its rules.” Id. 570/302(a). The Illinois Controlled Substances Act also authorizes the Department of Financial and Professional Regulation to discipline a practitioner holding an Illinois controlled substance license, stating that such license “may be denied, refused renewal, suspended, or revoked by the Department of Financial and Professional Regulation.” Id. 570/304(a).

Here, the undisputed evidence in the record is that Registrant currently lacks authority to handle controlled substances in Illinois because both his Illinois medical license and his Illinois controlled substance license are suspended. As discussed above, an individual must be a licensed practitioner and must hold a valid controlled substance license to dispense a controlled substance in Illinois. Thus, because Registrant lacks authority to handle controlled substances in Illinois, Registrant is not eligible to maintain a DEA registration. Accordingly, the Agency will order that Registrant's DEA registration be revoked.

Order

Pursuant to 28 CFR 0.100(b) and the authority vested in me by 21 U.S.C. 824(a), I hereby revoke DEA Certificate of Registration No. BW8048022 issued to Syed Warsi, M.D. Further, pursuant to 28 CFR 0.100(b) and the authority vested in me by 21 U.S.C. 823(g)(1), I hereby deny any pending applications of Syed Warsi, M.D., to renew or modify this registration, as well as any other pending application of Syed Warsi, M.D., for additional registration in Illinois. This Order is effective May 27, 2025.

Signing Authority

This document of the Drug Enforcement Administration was signed on April 18, 2025, by Acting Administrator Derek Maltz. That document with the original signature and date is maintained by DEA. For administrative purposes only, and in compliance with requirements of the Office of the Federal Register, the undersigned DEA Federal Register Liaison Officer has been authorized to sign and submit the document in electronic format for publication, as an official document of DEA. This administrative process in no way alters the legal effect of this document upon publication in the Federal Register .