as the basis for upholding the three-year suspension imposed by the Secretary.  Joudeh argues that the disqualification of his store is not warranted where the manager (Omar), with criminal intent and for his own advantage and to the disadvantage and detriment of the owner, illegally purchased food stamps and placed them (without knowledge of store owner) in the store cash register in exchange for cash.  Joudeh relies almost exclusively upon this court's opinion in Badwan v. United States, 541 F.2d 1388 (10th Cir.1976).


7
General Background--The Food Stamp Act of 1964


8
The Food Stamp Act of 1964, as amended, 7 U.S.C. Secs. 2011-2029, established a Food Stamp Program designed to insure that the abundance of food in the United States should be utilized by cooperative efforts of the Federalwho did not profit from the crime and who was not delict as a result of improper training, inadequate explanation, or negligent supervision of employees no agency inference was justified in imposing sanctions on the store owner.  Badwan involved a single criminal action.


10
The significant factual difference between Badwan and the case at bar, in our view, is that there was a minimum of supervision and oversight of the store operations by Joudeh, and the criminal violations occurred often over a substantial period of time.  Joudeh exercised virtually no control over inventory accounting at his store.  In effect, for a period of about six months, Joudeh performed no functions of control, management, oversight, or supervision at his store.  Furthermore, at the time of the violations