At the end of July, INTERPOL announced the execution of Operation Pangea XV, an annual week of coordinated law enforcement action to combat the illegal sale of medicines and medical products online. From June 23 to June 30, 2022, 94 member countries spanning every continent issued over 200 search warrants and opened over 600 investigations. Reports are still coming in, but thus far, authorities have seized over 3 million units (eg, pills, ampules, or bottles) of illicit, falsified, and misbranded medicines which were worth an estimated $11 million. In addition, 317,000 unauthorized coronavirus disease 2019 (COVID-19) test kits, worth over $3 million, were confiscated. In the process, they also shut down 4,000 web links and disrupted the operations of at least 36 organized crime groups.
History of Operation Pangea
Established in 2008 by INTERPOL and the Permanent Forum on International Pharmaceutical Crime in response to the growing prevalence of illegal online pharmacies, Operation Pangea aims to improve global cooperation and enforcement capabilities to disrupt the illegal pharmaceutical trade. Starting with only eight countries in 2008, Operation Pangea has grown significantly, at one point involving 123 countries. During its first decade, Pangea removed more than 105 million units from circulation, shut down 82,000 websites, and made 3,000 arrests.
Beyond removing dangerous medical products from circulation, Operation Pangea also helps to educate the public about the dangers of buying medicines from unregulated sources and allows participating countries to build on lessons learned from previous years to facilitate regional efforts to detect, investigate, and prosecute criminals trading in counterfeit and illicit medical products online.
Lessons From Operation Pangea
In the 14 years that Pangea has been running, it has revealed the following trends. Certain products are more popular online, but every year the offerings of illegal online pharmacies become more diverse. Consistent with prior iterations of Operation Pangea, one of the most prevalent medical products seized this year was erectile dysfunction medicines. However, since 2015, the types of medical products sold illegally online have grown. This year, regulatory authorities and officials in Northern Ireland discovered diazepam, pregabalin, inhalers, and tamoxifen among the 242,000 units of medicines seized. In Costa Rica, pre-filled syringes labeled “Tuberculin” were among the 11,187 units of unregistered, fake, and expired medicines seized at the border.
To advertise their products, illegal online pharmacies follow the same trends as legal online merchants, and social media and messaging apps have become popular means for criminals to reach consumers. This year, Operation Pangea reportedly shut down over 1,200 ads for counterfeit and illicit medicines across “all major platforms.”
Every year, the international networks that these illegal medical product sellers operate have become more complex and sophisticated. This year, while the majority of products were seized at United States borders, approximately half of the websites shut down in this operation were identified by authorities in Malaysia. As noted in INTERPOL’s press release, “the trade in illicit medicines extends far beyond any one country’s borders and is a significant global threat. Often, products are manufactured in one country and shipped to another, while advertisements for the medicines are hosted on websites based in many different countries.”
Whole-Of-Governments Approach to Combating Illicit Medicines
As a result of these trends and other lessons learned through Pangea, cross-country collaboration outside of the annual weeklong effort has grown more frequent in recent years. In 2017, in response to reports of illegal drugs being imported into the US through the United Kingdom, Food and Drug Administration (FDA) and the UK established their first bilateral enforcement operation – Operation Lascar. Over the past five years, Operation Lascar has led to over 80 criminal investigations and uncovered a variety of regulatory and legal gaps which criminals are exploiting to transship counterfeit medical products. For example, Lascar investigations revealed new distribution models that criminals have started to adopt, including efforts to infiltrate the regulated pharmaceutical supply chain by selling directly to physicians.
Building on these lessons, FDA Office of Criminal Investigation’s and the Organization of Economic Co-Operation and Development’s Task Force on Countering Illicit Trade recently announced the launch of a joint initiative to encourage wide-scale adoption of a “whole-of-governments” approach to combating illicit medical products. As a first step, the organizations have partnered on a two-day meeting in Paris on Sept 15-16, 2022, that will bring together leaders from industry, government, and the international community to explore regulatory and legal weaknesses and identify whole-of-governments solutions. More than 20 countries around the world and multinational organizations including the World Health Organization, World Customs Organization, INTERPOL, Europol, and Universal Postal Union have already expressed their support.
With global trade in illicit pharmaceuticals valued at $4.4 billion in 2016 and the surge of fraudulent activity observed during the COVID-19 pandemic, expect to see many more examples of international coordination like Lascar and Pangea in the near future.