Gold Fish Farms Faces Potential License Revocation by New Mexico Regulators
The New Mexico Regulation and Licensing Department (RLD) and its CCD have issued a Notice of Contemplated Action (NOCA) against Gold Fish Farms and Dispo, LLC, a licensed producer and manufacturer based in Veguita, New Mexico. The notice targets production license PROD-2022-0078-PRM-0001 and manufacturing license MANU-2023-0047.
What stands out most in this case is the CCD’s digital forensics work. The Department alleges multiple, serious violations of the CRA, and Uniform Licensing Act (ULA), including unlicensed production, falsification of BioTrack records, and continued operations after a license expired. If the respondents do not request a hearing within 20 days, the CCD may proceed with revocation, suspension, or fines—up to $10,000 per incident—without further judicial review.
Key Allegations
1. Operating Without a Valid License
The CCD states that Gold Fish Farms’ production license expired on April 26, 2025, yet inspectors found 242 mature plants and hundreds of immature plants still being cultivated three days later. By August 18, 2025, that count had risen above 500 mature plants, confirming ongoing production in violation of state law.
2. Failure to Renew License
Under §16.8.2.14 NMAC, operators must renew prior to expiration and cease operations once a license lapses. CCD alleges that Gold Fish Farms ignored this rule, continuing cultivation and manufacturing well past April 2025.
3. Missing Surveillance Footage
Across multiple inspections (Jan 2024 – Aug 2025), regulators found that several key grow and processing areas lacked required camera coverage, violating §16.8.2.10 NMAC.
4. Falsified Track-and-Trace Data
CCD investigators claim the company manipulated BioTrack entries—recording harvests that hadn’t happened and transferring plants electronically to the manufacturing license—to conceal production under an expired permit.
5. Inaccurate Inventory Reconciliation
Reports indicate major discrepancies between on-site inventory and BioTrack data. In one case, the system listed 1,000 plants, but only 150 were present. Later visits showed similar gaps, suggesting systemic recordkeeping failures.
6. Missing or Misused Plant Tags
Officers found untagged plants and frozen flower during every inspection. At one visit, tags provided by the operator corresponded to previously harvested crops, not current plants. In August 2025, roughly 200 pounds of fresh-frozen flower reportedly lacked any tags.
7. Absent Premises Diagram
Gold Fish Farms also failed to maintain an updated facility diagram—required documentation showing where each activity occurs—despite multiple reminders.
Evidence and Enforcement Process
The case is supported by inspection reports, photographs, officer testimony, and BioTrack audit data collected over nearly two years of site visits. Respondents have the right to:
Request a formal hearing under the ULA (§61-1-8 NMSA)
Be represented by counsel and subpoena witnesses
Review and cross-examine evidence presented by CCD
Digital Dash
During inspections in April and August 2025, investigators found more than 500 mature plants months after its production license expired on April 26. When regulators cross-checked the farm’s BioTrack account, they discovered that records showed a “harvest” event—plants logged as cut and processed—but the physical plants were still alive and in production. In other words, the digital told one story; the physical told another. In another instance when presented with plant tags, the BioTrack ID history did not check out in BioTrack.
And that’s what makes this case unique: CCD didn’t just rely on surface observations. They audited the digital backbone of New Mexico’s seed-to-sale system, something few licensees have faced before.
