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The 1988 Amendments In recognition of the fact that illegal drug trafficking in anabolic steroids and human growth hormone was becoming larger in scope and presenting an ever-increasing health risk to young athletes, Congress addressed the issue with two amendments, first in 1988 and then later in 1990. The purpose of both of these amendments was to criminalize steroid and human growth hormone trafficking. The first of these amendments was enacted as part of the 1988 Anti-Drug Abuse Amendments, Pub.L. No. 100-690, §§ 2401, 2403, and took effect on November 18, 1988. The 1988 Anti-Drug Abuse Amendments had two important components. The first was the creation of a new statute (codified at 21 U.S.C. § 333(e)(1)) which made the distribution of anabolic steroids illegal unless (1) it was done pursuant to the order of a physician, and (2) it was for the purpose of treating a disease. Pub.L. No. 100-690, § 2403. The second weapon that Congress added in 1988 to the government's arsenal to halt illegal trafficking in anabolic steroids and/or human growth hormone was the enactment of Pub.L. No. 100-690, § 2401. This provision, which was codified as 21 U.S.C. § 333a, gave the government the authority to seek forfeiture of property for felony crimes relating to any violations of the Federal Food, Drug, and Cosmetic Act involving anabolic steroids or human growth hormone. In pertinent part, 21 U.S.C. § 333a, provided:
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