Australia's biggest sheep exporter is facing a criminal investigation into conditions on board its Middle East-bound vessels.
Lawyers for Perth-based Emanuel Exports have reportedly returned a lengthy submission to a "show cause" notice by the Department of Agriculture for justification of why it should hold an export licence.
It comes after the release of footage by Animals Australia showing sheep in horrific conditions on board ships to the Middle East during the northern hemisphere summer in 2016.
The Agriculture Department confirmed on Friday a criminal investigation has been launched in response to the footage.
A spokeswoman confirmed it included allegations of overstocking, failing to have sufficient food and water available, animal injury and illness not being treated, and accredited vets and stockmen leaving vessels prior to unloading.
A number of witnesses are being questioned.
Emanuel Exports deferred comment to the Australian Livestock Export Council.
A spokesman told AAP it wasn't appropriate to comment while the investigation is underway, other than to say the company had always been fully-cooperative and compliant with requests and actions from the regulator.