FOIA Evidence Packet: Lobbying Influence and the Policy Narrative

Industry-Funded Travel Related to Indonesian Drug Policy Discussions

Source note: This section is based exclusively on emails and attachments released through Freedom of Information Act (FOIA) requests. The original records are linked below and provided in full so readers may independently review dates, participants, and logistics.

The records document a series of meetings and site visits in Indonesia involving U.S.-based researchers and other participants, with travel and logistics coordinated and funded by the American Kratom Association (AKA), a U.S. trade organization representing commercial interests.

At the time reflected in these records, Indonesian authorities were considering potential changes to export policy affecting kratom. Indonesia is the primary source of global supply, making regulatory developments there economically significant to U.S. importers and sellers.

What the records document

Emails and attachments show AKA staff coordinating and funding:

• International airfare for U.S.-based participants
• Hotel accommodations in Jakarta
• Airport transfers and local transportation
• Scheduled meals and group meetings
• Visits to farms and supply-chain locations

The communications reflect centralized planning of the itinerary, including scheduling, logistics, and group activities connected to meetings with Indonesian stakeholders.

Participation by publicly funded researchers

Some individuals involved in these meetings have conducted research supported by U.S. federal agencies, including NIH and NIDA. The records show that travel and on-the-ground logistics for this trip were arranged and paid for by a trade association with a direct commercial interest in the policy outcome under discussion.

These circumstances are relevant to questions of disclosure and independence when publicly funded research is presented in policy-facing settings organized by an interested industry group.

Indicators of coordinated presentation

One internal email included in the FOIA release references the distribution of branded apparel for participants during the trip:

“The AKA is designing a polo shirt for the kratom stakeholders to wear in Indonesia… Could you please provide your shirt size?”
— Internal email included in FOIA release

While not substantive in itself, this detail illustrates the level of coordination involved in the trip and the presentation of participants as a unified group.

Why these records are relevant

Industry-funded international travel connected to policy discussions raises questions about transparency, disclosure, and the distinction between independent scientific exchange and advocacy activity.

The records do not require interpretation to establish that a trade association financed and organized access to policymakers during a period of active regulatory consideration. These facts are documented directly in the emails and attachments.

Readers are encouraged to review the linked PDFs directly. All summaries above are drawn from the records as released and are provided for contextual clarity.

Industry-Organized Congressional Briefing

Source note: This section is based exclusively on emails and attachments released through Freedom of Information Act (FOIA) requests. The original records are linked below and provided in full for independent review of dates, participants, and logistics.

The FOIA records document the planning and execution of a congressional briefing organized by the American Kratom Association (AKA), a trade organization representing commercial interests. The materials show that the event was coordinated by the association rather than convened independently by congressional offices or public agencies.

Event organization and logistics

Emails and attachments reflect centralized coordination by AKA staff, including:

• Selection and sequencing of speakers
• Advance collection and review of slide presentations
• Scheduling and coordination within a congressional office building
• Hotel room reservations and room blocks
• Ground transportation arrangements
• Meeting setup and catering logistics
• Travel booking and reimbursement procedures

These records show that the association managed both substantive content and logistical support for the briefing.

Use of congressional facilities

The briefing took place inside a congressional office building. While such venues are commonly used for briefings, the setting can convey a level of institutional legitimacy to attendees and observers.

The FOIA materials indicate that the event itself was organized and financed by a private trade association, rather than sponsored or reviewed by a governmental or academic institution.

Travel reimbursement

One email in the record references reimbursement of travel expenses through the association:

“Please send travel receipts as soon as possible to our CFO, Tom Moore…”
— Internal email included in FOIA release

This correspondence documents that travel costs associated with participation in the briefing were processed as reimbursable expenses by the trade association.

Presentation of publicly funded research

The briefing materials reference research that cites support from U.S. federal agencies, including NIH and NIDA. The FOIA record shows that the briefing environment in which this research was presented was organized, scheduled, and funded by an industry group with a direct interest in the policy issues discussed.

These circumstances are relevant to questions of disclosure, context, and independence when publicly funded research is presented in policy-facing settings organized by interested parties.

Why these records are relevant

Congressional briefings can influence legislative understanding, oversight priorities, and regulatory timelines. The records presented here document how an industry organization coordinated access, logistics, and messaging in a congressional setting.

Readers are encouraged to review the linked PDFs directly. All summaries above are drawn from the records as released and are provided for contextual clarity.

Industry Coordination of Testimony at an Arkansas Legislative Hearing

Source note: This section is based exclusively on emails and attachments released through Freedom of Information Act (FOIA) requests. The original PDF is linked below and provided in full so readers may independently review dates, recipients, scheduling, and logistics.

The FOIA records document planning and logistical coordination related to testimony presented at an Arkansas interim committee hearing. Publicly, the hearing was described as an opportunity for legislators to receive expert information. The internal emails reflect significant involvement by the American Kratom Association (AKA), a trade organization representing commercial interests.

Coordination reflected in the records

Emails included in the FOIA release show centralized planning by the association, including:

• Advance discussion of witness order and sequencing
• Collection and review of presentation materials prior to the hearing
• Coordination of participant travel schedules
• Hotel accommodations arranged for multiple participants
• A scheduled private dinner with committee members in advance of testimony

These records indicate that the association played a role not only in facilitating attendance, but also in organizing the structure and timing of testimony.

Documented logistical involvement

One email included in the FOIA release states:

“AKA will make hotel arrangements… Dinner meeting with Committee members.”
— Internal email included in FOIA release

This correspondence documents that lodging and pre-hearing meetings with legislators were arranged by the trade association rather than by the legislature or an independent body.

Witness sequencing

The emails also reference the planned order of testimony, with scientific or technical witnesses scheduled to appear before other speakers. Such sequencing can affect how subsequent testimony is contextualized and evaluated by lawmakers.

The FOIA materials show that this sequencing was discussed and planned in advance.

Relevance to legislative review

Legislative hearings are often relied upon to distinguish between independent expertise and advocacy. The records presented here document the extent to which an interested trade organization coordinated logistics, scheduling, and access surrounding this hearing.

These facts are relevant to evaluating disclosure, context, and the degree of independence associated with testimony presented to lawmakers.

Readers are encouraged to review the linked PDF directly. All summaries above are drawn from the records as released and are provided for contextual clarity.

June 2024 Statement on 7-Hydroxymitragynine: Timeline Considerations

Source note: This section is based exclusively on the June 2024 written statement linked below. Readers are encouraged to review the full document to verify authorship, language, and timing.

In June 2024, a group of researchers released a written statement distinguishing traditional kratom products from formulations containing elevated levels of 7-hydroxymitragynine (7-OH) and mitragynine pseudoindoxyl.

The statement asserts that these higher-potency formulations “should not be scientifically considered or commercially categorized as kratom products” and characterizes their presence in the marketplace as a “recent appearance.”

Timeline reflected in the statement

By describing products containing elevated 7-OH and mitragynine pseudoindoxyl as a recent market development, the authors place their emergence close in time to the statement’s 2024 publication.

This timing is relevant because reported adverse outcomes associated with kratom — including dependence, withdrawal, overdose, and death — are documented in FDA adverse-event reporting, CDC surveillance data, poison control records, and published case reports dating back many years prior to 2024.

The harms cited in regulatory and public-health discussions therefore predate the timeframe in which the statement indicates these newer formulations entered the market.

Implications for attribution of harm

If products containing elevated 7-OH and mitragynine pseudoindoxyl are, as the statement describes, a recent development, they cannot account for the majority of historical adverse events that occurred before their reported emergence.

This creates a chronological inconsistency when the statement is cited to suggest that previously documented harms should be attributed primarily or exclusively to these newer formulations.

Relevant language from the statement

“Such products should not be scientifically considered or commercially categorized as kratom products.”
“The recent appearance of 7-OH mitragynine and mitragynine pseudoindoxyl products…”
— June 2024 written statement

Read together, these statements acknowledge that the compounds being distinguished emerged after many of the adverse outcomes that have informed regulatory concern.

Why this record is relevant

Policymakers evaluating public-health risk often consider both the nature of a product and the historical record of harm. The timeline described in this statement is relevant because it does not align with the long-standing body of reported adverse outcomes associated with products sold and consumed as kratom.

This discrepancy is not inferred; it arises directly from the authors’ description of when certain formulations entered the market relative to when documented harms occurred.

Readers are encouraged to review the linked statement directly. The observations above are drawn from the document’s own language and the publicly available chronology of reported adverse events.

Industry Participation in Drafting a Scientific Statement

Source note: This section is based exclusively on correspondence released through Freedom of Information Act (FOIA) requests. The original PDF is linked below and provided in full so readers may independently review dates, participants, and language.

The FOIA records document direct involvement by an industry advocate in the drafting and revision of a written statement presented as a scientific communication for policymakers. The correspondence shows that proposed language changes were discussed with academic researchers whose work is frequently cited in policy contexts.

In April 2024, JW Ross, identified in the emails as a senior strategist with the Global Kratom Coalition, commented on draft language in a statement intended for submission to a legislative health committee. Recipients of the email included academic researchers affiliated with university programs, along with other contributors to the statement.

Documented language revision request

The correspondence reflects an objection to draft wording indicating that certain formulations “may confer a higher risk profile.” The proposed revision focused on changing the degree of certainty expressed in the sentence.

“If this is your position then I would suggest that ‘may’ be changed to ‘would’ so that it’s clear that that’s your intent. The reason this is so important is that if we have ambiguity, it’s fertile ground for those who want to ban all kratom.”
— Email dated April 2, 2024, included in FOIA release

This exchange documents that the rationale for the suggested change was framed in terms of anticipated regulatory interpretation rather than evidentiary clarification.

Role of non-academic participants

The FOIA record identifies the individual proposing the language change as an industry advocate rather than a researcher or study author. The emails show participation in line-level drafting discussions for a document later characterized as a scientific statement.

The correspondence does not reflect a recorded objection within the email thread to the premise of the proposed revision or to the involvement of an industry advocate in shaping the wording.

Disclosure considerations

The FOIA materials do not indicate that subsequent public uses of the statement disclosed that specific wording had been proposed or influenced by an industry representative for regulatory or strategic reasons.

These circumstances are relevant when evaluating how scientific language presented to policymakers was developed and whether readers were provided sufficient context regarding external participation in the drafting process.

Why this record is relevant

Policymakers often rely on scientific statements for their measured language, uncertainty qualifiers, and independence from advocacy. The correspondence presented here documents how language intended for legislative audiences was discussed and revised in consultation with an interested industry participant.

Readers are encouraged to review the linked correspondence directly. All observations above are drawn from the language and context contained in the FOIA-released emails.

Trade Association “GMP Standards” Program and Regulatory Context

Source note: This section is based exclusively on the “GMP Standards Program 3.0” presentation linked below. Readers are encouraged to review the slides directly to verify scope, administration, and enforcement provisions.

The materials titled “GMP Standards Program 3.0,” developed by the American Kratom Association (AKA), describe a voluntary quality program administered by a trade organization representing commercial interests. The slides use terminology and structural elements similar to those found in federal Good Manufacturing Practice (GMP) regulations applicable to dietary supplements.

The presentation does not indicate that the program is administered, approved, or enforced by the U.S. Food and Drug Administration (FDA) or any other governmental authority.

Use of dietary supplement GMP terminology

The slides reference concepts and language commonly associated with dietary supplement GMPs (e.g., 21 C.F.R. Part 111). The presentation format may suggest the existence of a recognized regulatory framework applicable to the products discussed.

FDA communications, including public advisories, warning letters, and import alerts, have stated that kratom does not qualify as a lawful dietary supplement or approved food additive. As a result, dietary supplement GMP regulations do not constitute a federal compliance pathway for these products.

Program structure as described in the slides

According to the presentation, the program is voluntary and administered by the trade association. The materials do not describe:

• Oversight by an independent regulatory body
• Publicly available audit findings
• Mandatory corrective actions with defined timelines
• Enforceable penalties for noncompliance
• Authority to mandate recalls or product withdrawal
• Referral mechanisms to FDA or state enforcement agencies

The program is presented as a set of standards and guidance rather than as an enforceable regulatory system.

Labeling guidance

One slide addressing labeling states:

“The label… shall not infer in any way the product will produce a ‘high’ to a consumer.”

This instruction reflects an effort to limit certain claims in marketing materials. The slides do not describe how compliance with this guidance is monitored or enforced, or what actions are taken in response to violations.

Emphasis on voluntary compliance

The presentation emphasizes collaborative and phased approaches, including guidance documents, webinars, and model standard operating procedures. The materials do not identify mandatory sanctions or exclusion from the marketplace for failure to meet program expectations.

Relevance for policymakers

The GMP Standards Program has been cited in policy discussions as evidence that the products in question can be subject to responsible oversight. The slides clarify that the program operates without governmental authority, independent enforcement, or mandatory consequences.

These characteristics are relevant when evaluating claims that a voluntary trade-association program provides protections comparable to formal regulatory oversight.

Readers are encouraged to review the linked slides directly. The scope and limitations of the program are described within the presentation itself.

University Correspondence Regarding Product Distinctions and Uncertainty

Source note: This section is based exclusively on an email chain involving University of Florida personnel, released through public-records requests. Readers are encouraged to review the linked PDF directly to verify dates, participants, and language.

The email correspondence documents internal discussion among academic researchers, industry representatives, and advocates regarding differences between kratom leaf material and more concentrated product forms.

On January 27, 2024, University of Florida pharmacologist Dr. Oliver Grundmann wrote to trade-association leadership, extract manufacturers, and other researchers regarding product categorization and regulatory treatment.

“Extracts and concentrates do have a place and should be available to consumers. But they are also distinct in many regards from native kratom leaf material…”
— Email dated January 27, 2024

This statement reflects an acknowledgment that extracts and concentrates differ from leaf material in relevant respects, including chemical composition and potential effects.

Discussion of chemical variability and uncertainty

The same email thread also references uncertainty regarding the contribution of individual alkaloids and other compounds:

“As Chris [McCurdy] likes to point out, the contribution of each alkaloid (and potentially other, yet unknown compounds) is like a symphony…”
— Same email thread

This language acknowledges variability, interaction effects, and incomplete understanding of how individual components may contribute to overall pharmacological outcomes.

Comparison to public representations

In public policy discussions, kratom products are often described as a single category without distinction among leaf material, extracts, or concentrates. The internal correspondence reflects a more differentiated understanding of product types and associated uncertainties.

Internal assessment of regulatory risk

The email chain also includes commentary from an industry strategist regarding potential regulatory consequences:

“It’s just a matter of time till enough people get hurt by these products and all kratom gets banned.”
— Statement included in the same email thread

This remark reflects internal concern about injury risk and the possibility of broader regulatory action affecting all products in the category.

Relevance for policymakers

Policymakers often rely on expert testimony to assess product consistency, predictability, and risk. The correspondence presented here documents internal acknowledgment of product distinctions, chemical complexity, and uncertainty that may not be apparent in simplified public descriptions.

These records are relevant when evaluating the completeness and context of scientific representations made in legislative or regulatory settings.

Readers are encouraged to review the linked correspondence directly. All observations above are drawn from the language of the emails as released.