🫠 Psychonaut POV

Welcome to Tricycle Day. We're the psychedelics newsletter that sells seashells by the seashore. Hey, don’t knock our side hustle. 🐚 

Raúl Reichard is an attorney who had a hand in Puerto Rico’s recent psychedelics executive order. Thanks to him, your next journey could involve some tropical rainforest integration. No guarantees, but he's optimistic (in a lawyerly sort of way).

We asked Raúl how Puerto Rico became a leader in psychedelic policy reform, what role the island's copious drug factories could play, and how relevant this news is to Americans on the mainland.

Over 10 million U.S. adults microdosed in the past year.

Microdosing is the most popular way people use psychedelics today. Yet somehow this phenomenon has been mostly ignored by the big events in the space.

So on October 21, the nonprofit Microdosing Collective is hosting The Microdosing Summit in the Texas Hill Country just outside Austin.

They’ll have panels and presentations, of course. But beyond that, you can expect wellness activations, brand showcases, live music, and comic relief.

We’ll be there, and we got you the hookup.

My path was personal before it became professional, like with a lot of people in this field. I came to psychedelic medicine partly through my own search for healing, which I found through ketamine-assisted psychotherapy alongside other traditional entheogens. That led me to look for a way to marry healing and the law. 

I pursued formal training through CIIS in psychedelic-assisted therapies, because I didn't think I could responsibly work in this field understanding only the legal side. I wanted to understand the medicines, indigenous wisdom, the clinical context, ethics, and the patient experience, too. 

From there, my practice expanded from business law into advising entheogenic organizations at the intersection of controlled substances law and religious freedom. I also started advising our client, the Pravan Foundation, which led to my involvement in the Puerto Rico ibogaine initiative. More recently, I co-founded the Psychedelic Ethics Project with my wife and law partner, an initiative focused on informed consent, patient protection, and harm reduction that grew largely out of my own experience with an esketamine protocol for treatment-resistant depression.

Ibogaine became especially meaningful to me because of its relevance to veterans. My great-great-uncle was the first Puerto Rican general and Westpoint graduate, and both my grandfathers served in wars. One came home from Korea with what we'd now diagnose as severe PTSD, and it left him with alcohol abuse and nightmares for the rest of his life. I often wonder whether ibogaine could have helped him, and whether it would have curtailed significant generational trauma.

Much of what I've spent significant time and resources healing myself likely passed down that line. And so, in my view, when you treat a veteran, you're not just healing the patient; you're saving other people from trauma too.

Our initiative far predates President Trump's April 18 executive order. We were already exploring what Puerto Rico could do responsibly around ibogaine, particularly for veterans and other populations with unmet needs. That said, the federal action changed everything. It created real momentum around psychedelic research, veterans, federal and state collaboration, and funding. I think of it as an accelerant rather than the genesis of the Puerto Rico effort.

What the governor signed was deliberately careful and measured, and I have praised her publicly for her leadership. The order doesn’t legalize or authorize treatment with ibogaine or with any other psychedelic. Instead, it directs the Department of Health to evaluate whether a clinical research pilot program involving ibogaine and potentially other emerging therapies is scientifically, ethically, operationally, and financially sound.

Our Department of Health has unusual autonomy and holds the authority to reschedule substances under the local Controlled Substances Act, and it has done so before. The executive order doesn't limit itself to ibogaine either; it names other emerging therapies including MDMA and psilocybin. The government didn't decide whether these therapies work. It set up a responsible way to find out.

Now we wait for the Department of Health to name a multidisciplinary scientific and regulatory advisory committee and, once that's official, the milestones in the executive order kick in. It starts with an initial report at 45 days, then a final report and recommendation at 120 days advising the governor whether moving forward is a good idea. If the science and feasibility analysis support it, the next step is to launch a clinical research-driven pilot program prioritizing and treating veterans in Puerto Rico.

The committee can look at other compounds, and I hope it does, but the focus will be on ibogaine. Part of the reason ibogaine has attracted particular attention is that it presents a somewhat different policy profile from many classic psychedelics. It has not historically been associated with recreational use, while its potential relevance to substance-use disorders and veterans has generated significant research and now popular interest. At the same time, ibogaine carries potentially serious cardiovascular risks, which is precisely why rigorous medical screening, monitoring, and an appropriate clinical setting are so important. As such, any future clinic model will need a robust licensing and permitting framework. But we're going step by step. The plan is to run the pilot, gather the data, and then see where the evidence leads. 

And that was the takeaway from the Summit the Pravan Foundation put on in San Juan after the signing: Puerto Rico's goal shouldn't be to move the fastest; it should be to get this right, and build something worthy of trust and replication by other States and jurisdictions.

Thinking about a career in psychedelic therapy? Believe it or not, there’s no prior education required. Join Numinus’s free Info Friday session on 9/25 to see how to get started. (Code ALTHEA10 will take 10% off any course.)

That's one of the most interesting parts of the opportunity, because Puerto Rico isn't starting from zero. For decades the Island has been one of the most important pharmaceutical and medical device manufacturing centers in the United States and, really, the world. We have extensive life sciences infrastructure, excellent universities and hospitals, and deep experience operating in highly regulated environments. Our most important resource is human capital: a highly skilled bilingual workforce already well-versed in the demands of an FDA-regulated industry.

I also see genuine possibility on the supply side, which is important because sourcing is one of the bottlenecks to access. There's potential for growing iboga in Puerto Rico, since our climate is quite similar to where the plant grows natively in Central Africa. Ibogaine can also be semi-synthesized and, given our pharma infrastructure, I see potential on the manufacturing side too.

That's way ahead of us, however, so I won’t speak on behalf of the forthcoming committee. Suffice it to say that any future pathway would ultimately have to address the federal controlled-substances framework and involve appropriate coordination with DEA and other federal regulators. 

Either way, the opportunity here isn't to become an offshore workaround as Puerto Rico is a U.S. jurisdiction. What we're asking is how a world-class life sciences ecosystem that already exists can participate in the next generation of medicine.

If Puerto Rico can generate the safety and efficacy data, develop the protocols and patient protection standards, and show how local and federal regulators can work together, that knowledge doesn't stop at the shoreline. It contributes to a national evidence base, informs clinicians elsewhere, and gives other jurisdictions a model to study, replicate, and improve upon.

The longer-term vision is what excites me. If the science supports these therapies and the federal approvals or exemptions follow, I can imagine Puerto Rico becoming home to centers of excellence and clinics, where patients from across the country receive treatment within the United States with every medical and safety safeguards that entails. There could be a day when a veteran from California or Texas comes to Puerto Rico without a passport and integrates somewhere like El Yunque, the largest tropical rainforest in the U.S. But we’re not there yet. 

Right now we're at an inflection point. As the science advances and governments engage seriously, the legal conversation is getting more sophisticated. We're moving from “can we do this” to “how should we do this,” and that's increasingly where I see my work. There's tremendous opportunity for healing in front of us, but there’s also tremendous opportunity to get a lot of it wrong.

I don't look at a proposed law or regulation and see only statutory language anymore. I think about the person who will eventually be sitting in the treatment room, who screened them, who's qualified to be with them, what they consented to, and who's accountable if the system fails them. Those questions determine whether a framework truly protects people or merely looks good on paper. In Puerto Rico, that means engaging directly with veterans and their advocates to understand what they actually need, where the existing system is falling short, and what meaningful access and protection would look like from their perspective. I’d much rather build policy with the humans on the other end of it than from an ivory tower.

Get to know Reichard Tornes, PLLC and the Psychedelic Ethics Project.

That’s all for today, Cyclists! Whenever you’re ready, here’s how we can help.

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DISCLAIMER: This newsletter is for educational and informational purposes only and is not intended as a substitute for professional medical advice. The use, possession, and distribution of psychedelic drugs are illegal in most countries and may result in criminal prosecution.