Ex-employee of Flock here, that's ABSOLUTELY what's happening.
And what's more Flock lets them do so even when they know the agencies are legally not permitted to do so. They turn a blind eye, say it's not their problem to enforce ("oh, doing so in state X is illegal? Well, even if your agency is in state X, we didn't disable that feature"), then happily provide training to do enable those agencies to do so (and it's a nudge nudge wink wink part of the sales process.)