Counterfeit Pharmaceuticals

Criminals fabricate or re-label medicines with falsified or substandard ingredients and distribute them via unregulated or online marketplaces, often exploiting weak legislation or low deterrent penalties in certain jurisdictions. They commonly rely on digital marketing techniques and targeted advertising to reassure unsuspecting buyers about product authenticity, while maintaining minimal transparency regarding production or supply chains. At the point of sale, they may only lightly disguise the illegal nature of the goods, but the primary aim is to secure illicit revenue that can later be laundered. Major international law enforcement efforts, such as Operation Pangea, regularly uncover large-scale cross-border shipments of counterfeits, underscoring the global reach of this method and the challenges posed by anonymity and minimal oversight in these marketplaces.

[
Code
T0143.003
]
[
Name
Counterfeit Pharmaceuticals
]
[
Version
1.0
]
[
Parent Technique
]
[
Risk
Channel Risk, Jurisdictional Risk
]
[
Created
2025-02-12
]
[
Modified
2025-04-02
]

Falsified Medical Products

Tactics

The main goal is to produce criminal proceeds by selling counterfeit or falsified medicines, forming the illicit capital to be laundered later.

Risks

RS0003
|
Channel Risk
|

Criminals exploit unregulated or poorly monitored online marketplaces and digital channels to distribute counterfeit pharmaceuticals. The minimal KYC and lack of direct oversight allow large-scale sales of falsified products, generating illicit proceeds beyond standard AML checkpoints.

RS0004
|
Jurisdictional Risk
|

Counterfeiters exploit regions with weak legislation or low deterrent penalties to produce and distribute falsified pharmaceuticals. The cross-border movement of these goods through such jurisdictions hampers law enforcement efforts and bolsters the global reach of this illicit trade.

Indicators

IND01426
|

Large monetary transactions or structured payments that significantly deviate from normal trade volumes for legitimate pharmaceutical products.

IND01427
|

Frequent cross-border transfers of funds tied to medical products, directed to or from jurisdictions with weak regulatory oversight.

IND01428
|

Multiple small transactions in a short timeframe, each below reporting thresholds yet collectively representing significant value for medical product sales.

IND01429
|

Frequent usage of cryptocurrency or digital wallets for medical product payments on unregulated online platforms.

IND01431
|

Inconsistencies in invoices, such as misaligned product descriptions, quantities, or pricing relative to standard market rates for genuine medicines.

IND01433
|

Frequent updates to supplier or beneficiary account details in customer profiles linked to medical product transactions, especially in online or informal marketplaces.

IND01435
|

Utilization of online marketplaces and digital platforms where seller identities are unverifiable and paper trails are minimal, favoring the distribution of falsified medical products.

IND01437
|

Discrepancies between shipping address and invoiced address in medical product transactions, indicating rerouting or misrepresentation.

IND01439
|

Links between customers and entities known to operate in high-risk networks or with past flags for involvement in counterfeit trade during customer due diligence checks.

IND01441
|

Lack of proper certification, licensing, or product authenticity documentation from suppliers, as revealed during due diligence processes targeting falsified medical products.

IND01443
|

Frequent refunds or chargebacks referencing substandard or undelivered pharmaceuticals, indicating potential counterfeit distribution.

IND01444
|

Significant online advertising or marketing expenditures for unverified pharmaceutical brands lacking recognized licensing or official channels.

Data Sources

Consolidates negative news articles, legal actions, and court documents, revealing known or alleged involvement in counterfeit trade, relevant criminal proceedings, or regulatory violations.

Contains comprehensive records of goods entering or leaving a country, details on shipping routes, bills of lading, and declared contents. This supports the detection of cross-border shipments of counterfeit pharmaceuticals and enables targeted AML investigations of illicit trade routes.

Verifies supplier and distributor credentials, including licensing and professional affiliations, to help identify unlicensed entities claiming to deal in pharmaceutical products.

Includes public data from websites, social media, and other open channels, enabling the monitoring of unregulated online marketplaces, suspicious digital advertising, and unverifiable pharmaceutical brand promotion to help detect counterfeit medicine networks.

Captures invoice and contractual details, such as product descriptions, quantities, and pricing, enabling the detection of misalignments or unusual terms that may indicate falsified medical products.

Includes official records of seized shipments and assets, enabling the identification of known counterfeit pharmaceutical trafficking routes and the parties involved in illicit trade.

Provides comprehensive records of all financial transactions (e.g., timestamps, amounts, parties) to detect patterns indicative of counterfeit pharmaceutical sales, such as large bursts of structured payments, multiple low-value transfers, or frequent refunds and chargebacks.

Tracks e-wallet and digital payment usage, including transaction details, user identifiers, and refund/chargeback records. This helps detect potentially fraudulent or excessive refunds tied to substandard pharmaceuticals.

Provides bills of lading, import/export declarations, and shipping details, assisting in cross-checking declared versus actual goods and detecting rerouted or disguised counterfeit pharmaceuticals.

Houses verified customer profiles, beneficial ownership data, and ongoing due diligence updates, enabling the detection of high-risk or frequently changing suppliers and beneficiaries in counterfeit pharmaceutical schemes.

Captures cryptocurrency wallet addresses, transaction flows, and analytics to support the identification of unregulated digital payments and laundering methods linked to counterfeit pharmaceutical sales.

Details cross-border funds flow and participating financial institutions, facilitating the detection of suspicious international transfers linked to unregulated pharmaceutical shipments or payments.

Mitigations

Require in-depth verification of pharmaceutical suppliers or distributors operating in high-risk jurisdictions or unregulated online marketplaces. Confirm official manufacturing or distribution credentials, check for prior enforcement actions involving falsified medicines, and scrutinize beneficial owners to uncover connections to illicit pharmaceutical operations.

Obtain and validate detailed information from businesses dealing in medical products, ensuring legitimate pharmaceutical licenses, proof of authorized distribution, and appropriate business addresses. By verifying legitimacy during onboarding, institutions can block counterfeit pharmaceutical operators from accessing financial services.

Implement targeted transaction monitoring policies for pharmaceutical-related payments. Flag anomalies such as repeated small transactions below reporting thresholds, abrupt large orders not aligned with typical medication inventories, or cross-border flows routed through jurisdictions with lax pharmaceutical controls. This approach directly intercepts illicit proceeds tied to counterfeit drug sales by isolating suspicious payment patterns early.

Deliver focused training to employees handling pharmaceutical-related accounts or payments, emphasizing unique counterfeit medicine red flags such as unverified supplier credentials, dubious online marketplaces, or mismatched product documentation. This enables staff to promptly identify and escalate suspicious activity linked to falsified pharmaceuticals.

Use escrow arrangements for high-value pharmaceutical transactions, releasing payments only upon confirmation that the goods meet recognized quality standards and regulatory approvals. This structure prevents immediate access to funds from counterfeit sales by withholding disbursements until legitimacy is confirmed.

Cross-check client-provided pharmaceutical credentials and claimed regulatory approvals with publicly available data, such as medicine registries and health authority advisories, as well as third-party reviews. This process helps identify unapproved suppliers, falsified product authorizations, or blacklisted entities involved in counterfeit medicine distribution.

Participate in collaborative initiatives with regulators, peer institutions, and law enforcement to exchange data on emerging counterfeit pharmaceutical schemes, known illegal distributors, and newly identified online platforms selling falsified medicines. This coordinated intelligence approach disrupts networks by rapidly identifying and blocking their financial pathways.

Deny or limit access to banking services for clients unable to produce valid pharmaceutical licenses or who repeatedly fail authenticity checks. This restricts illicit operators from freely trafficking counterfeit medicines by curtailing their use of financial channels.

Examine shipping and invoicing details for pharmaceutical shipments, comparing declared products against official market prices and recognized labeling. Investigate discrepancies in quantity, packaging, or licensing documentation that may signal falsified or substandard medicines disguised as legitimate pharmaceutical trade.

Instruments

  • Criminals deposit or receive counterfeit pharmaceutical proceeds into personal or business bank accounts, often without raising immediate suspicion if transactions appear routine.
  • They may commingle illicit funds with legitimate sales or distribute them across multiple accounts to layer transactions, complicating efforts by authorities to trace the beneficial ownership of the funds.
  • Criminals convert revenue from counterfeit pharmaceutical sales into cryptocurrencies using peer-to-peer exchanges with minimal KYC requirements.
  • Funds can be moved quickly across different wallets or swapped into various tokens, creating a complex transaction trail that frustrates investigators seeking to trace the original illicit proceeds.
  • Criminals store gains from falsified medicine sales in self-hosted or weakly regulated wallets, reducing KYC exposure.
  • They easily transfer funds among multiple addresses or combine them with legitimate transactions, adding layers of obfuscation before eventual cash-outs.
  • Through online marketplaces, criminals accept payments for counterfeit medicines via credit and debit cards, mislabeling the nature of these purchases.
  • They also exploit chargebacks or refunds to obscure the actual purpose behind the transactions, further complicating the traceability of illicit funds.
  • Criminals issue paperwork reflecting legitimate pharmaceutical goods but ship counterfeit or substandard products instead.
  • By presenting false invoices, they create the appearance of normal commercial transactions; this trade-based approach conceals the illicit nature of the funds behind document-driven processing steps.
  • Criminals use prepaid cards or e-wallets to collect and hold proceeds from pharmaceutical sales, benefiting from limited customer verification.
  • Multiple instruments can be loaded with smaller amounts to avoid triggering reporting thresholds, then aggregated or transferred elsewhere to layer and obscure the source of funds.

Service & Products

  • Allow direct conversion of illicit earnings from falsified pharmaceutical sales into cryptocurrency without centralized oversight.
  • Minimal KYC requirements and the option to transact under false identities make these platforms attractive for obscuring money flows.
  • Criminals list falsified or substandard medical products on online marketplaces, circumventing regulatory oversight and concealing the nature of these goods.
  • Minimal scrutiny and global reach enable large-scale sales of counterfeit pharmaceuticals, generating proceeds to be laundered later.
  • Criminals arrange cross-border shipments of counterfeit medicines, often mislabeled or with falsified documentation to conceal the illicit nature of the goods.
  • Large-scale international shipping supports widespread distribution and complicates law enforcement tracking.
  • Enable criminals to receive and store proceeds from counterfeit medicine sales under pseudonymous or weakly verified accounts.
  • Facilitate quick transfers to other wallets or services, complicating tracing and allowing layering of illicit funds.
  • Enables international transfer of funds tied to the sale of falsified pharmaceuticals, often routed through jurisdictions with weak oversight.
  • Criminals may structure or layer transactions across multiple accounts to mask beneficial ownership and distance funds from their illicit origin.
  • Facilitate rapid payment processing for counterfeit pharmaceutical transactions, often lacking robust KYC/AML controls.
  • Criminals can mislabel products or transactions, obscuring the illicit nature of proceeds, and exploit chargebacks or refunds to further mask the flow of funds.

Actors

Criminals list counterfeit medicines on these platforms, exploiting weak verification and oversight. By connecting large numbers of buyers and sellers across multiple jurisdictions, online marketplaces:

  • Provide a global reach for distributing falsified products.
  • Facilitate anonymous or pseudonymous transactions, limiting transparency for financial institutions.

These providers process online payments for counterfeit pharmaceutical sales, often relying on limited product information or mislabeled transactions. Criminals exploit:

  • Rapid payment settlement to move illicit proceeds quickly.
  • General-purpose or unverified merchant accounts, concealing the true nature of transactions from financial countermeasures.

Illicit operators use legitimate shipping channels to move falsified medicines across borders. Frequent tactics include:

  • Mislabeling or falsifying shipment documentation to obscure the true contents.
  • Exploiting large-scale international networks, complicating efforts to trace the flow of counterfeit goods and related funds.

Criminals convert proceeds from counterfeit pharmaceutical sales into cryptocurrency via decentralized trading. Such operators:

  • Allow direct matching of buyers and sellers of digital assets without centralized oversight.
  • Enable pseudonymous transactions, making the detection of illicit proceeds more difficult for financial institutions.

Counterfeit drug manufacturers produce or repackage falsified pharmaceuticals for illicit distribution. By operating outside regulated supply chains and misrepresenting substandard ingredients, they accumulate proceeds that require laundering. Their activities include:

  • Sourcing cheap or unregulated materials in jurisdictions with minimal enforcement.
  • Directing online distribution channels that obscure true product quality and authenticity from end buyers, undermining financial institutions’ ability to detect illicit revenue sources.

References

  1. GIABA (Inter-Governmental Action Group Against Money Laundering in West Africa). (2017). Money laundering resulting from the counterfeiting of pharmaceuticals in West Africa. GIABA. https://www.giaba.org/publications/publication_3030.html

  2. Armberger, L., Craig, C., De Vivo, A., McNamee, J., Puttonen, R. (2021). Policymaking and the role of online intermediaries in preventing and combating illicit trafficking. United Nations Office on Drugs and Crime (UNODC). https://sherloc.unodc.org/cld/uploads/pdf/Online_intermediaries_eBook.pdf

  3. Lavorgna, A. (2015). Organised crime goes online: Realities and challenges. Journal of Money Laundering Control, Vol. 18 No. 2, pp. 153-168. https://doi.org/10.1108/JMLC-10-2014-0035