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Insights and Expertise




        Online healthcare                                       The risk of online pharmacies

        and the challenges                                      In early 2024, 52 percent of Americans reported hav-
                                                                ing purchased medication from an online pharmacy—a
                                                                number that continues to rise (see http://bit.ly/4m0Eicm).
        ahead for FIs                                           This demand has spurred fierce competition in the sec-
                                                                tor, as traditional pharmacies battle tech-forward startups
                                                                for patient dollars. Advertisements, emails, social media
                                                                posts and sponsored videos flood online platforms, and
                                                                many consumers bargain-hunt for providers offering the
                                                                cheapest treatments.

                                                                However, some of the most visible, accessible offerings are
                                                                also among the most problematic. Scammers and bad ac-
                                                                tors are exploiting the high demand and low inventory of
                                                                products like GLP-1 weight loss drugs.
                                                                For example, soaring demand for GLP-1 drugs in the past
                                                                year has driven unsuspecting consumers toward online
                                                                providers offering unregulated and fraudulent products.
                                                                When access to compounded GLP-1s increased, so did
                                                                pathways for harmful products to slip by undetected. By
        By Tom Cook                                             mid-November 2024, one branded GLP-1 seller reported
                                                                serious health outcomes linked to compounded versions
        LegitScript                                             of its product, some fatal.

                   nline healthcare has surged in popularity,   Consumers have reported problems with their online
                   first catapulted by the COVID-19 pandemic's   medicine as well, including one woman whose GLP-1
                   acceleration of healthcare digitalization, then
        O boosted by niche telehealth startups offering         medication  was  actually  fast-acting  insulin  and  nearly
                                                                killed her, according to Healthcare Packaging.
        customized care.
                                                                The  problem  extends  to  all  types  of  prescription  drugs,
        While this streamlined approach to obtaining medica-    but especially controlled substances.  In  another  tragic
        tions and medical advice may be convenient and appeal-  case, a woman unknowingly purchased counterfeit oxyco-
        ing, the CDC reported that as many as 95 percent of online   done laced with fentanyl and methamphetamine from an
        pharmacies operate outside of the regulatory framework,   online pharmacy that falsely claimed to be FDA-approved
        breaking jurisdictional laws, advertising unapproved    (see  http://bit.ly/45YiOGY). Counterfeit pharmaceuticals
        treatments, and even selling counterfeit products.      can have deadly consequences, making the need for stron-

                                                                ger safeguards and enforcement even more urgent.
        With consumer safety at risk, enforcement agencies like
        the U.S. Department of Justice have endeavored to combat   What lies ahead for payment facilitators
        fraud in the telemedicine sector. Recently, the DOJ uncov-
        ered a $1.7 billion international telemedicine scheme in-  Risk experts expect fraudulent activity to evolve further
        volving fraudulent prescription billings from more than   this year as bad actors leverage rapid technological ad-
        50 pharmacies in the United States, in which fraudsters   vancements to circumvent evolving regulations and com-
        posed as beneficiaries to trick doctors and installed soft-  pliance measures. For FIs facilitating card-not-present
        ware that replicated real prescriptions.                transactions for healthcare-related businesses, the stakes
                                                                are especially high.
        However, while enforcement action has disrupted some
        operations, these cases highlight cybercriminals' growing   Card networks often categorize such transactions as high-
        sophistication and their ability to exploit consumers, busi-  integrity risk, meaning there is an elevated risk of illegal
        nesses, ecommerce platforms and financial institutions   activity that can cause consumer harm. These healthcare
        (FIs) using advanced strategies and technologies. Tactics   merchants,  which  typically  fall  into  merchant  category
        like misleading advertisements, AI-generated customer   codes 5122 or 5912, require institutions  like acquiring
        interactions, and counterfeit credentials enable them to   banks, payfacs and ISOs to have extra controls in place to
        evade detection and deceive consumers.                  ensure compliance.

        FIs that process payments from these merchants are      The balance is critical between managing merchant risk
        uniquely positioned to safeguard the marketplace and    and maintaining a seamless consumer experience. Failure
        proactively combat these threats to public health.      to implement proactive risk management strategies may

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