Kim

This appeal requires us to decide, among other things, whether a grocery store owner may be permanently disqualified from participating in the Food Stamp Program because one of his employees illegally trafficked in food stamps without the owner’s knowledge. We hold that he may and affirm the district court’s grant of summary judgment upholding the disqualification.

I.

On April 24, 1992, Kim applied as the owner of Jones Market to participate in the Food Stamp Program, a welfare program administered by the Food and Consumer Service (“FCS”), an agency in the Depart *1271 ment of Agriculture, pursuant to the Food Stamp Act (the “Act”). The program allows authorized stores to accept food coupons issued by the Department of Agriculture as payment for food items. However, an authorized grocery store may be fined a civil money penalty or disqualified from participating in the Food Stamp Program for a specified period of time or permanently for violating any of the provisions of the Food Stamp Act or its implementing regulations. See 7 U.S.C. § 2021 (a), (b); 7 C.F.R. § 278.6 (a). Expressly forbidden is “trafficking” in food stamps, that is, the buying or selling of coupons for cash or…