Cases such as these blur the line between cargo theft, counterfeiting, and diversion, and each of the instances above could plausibly be described as all three types of incidents. Rather than thinking of these risks as distinct and separate, pharmaceutical companies would benefit by thinking of them as interrelated, with similar risk factors driving all three. Stolen pharmaceuticals can re-enter legitimate supply chains or be tampered with and comingled with counterfeit drugs; similarly, criminals can take advantage of cracks in legal or quasi-legal parallel trade arrangements to funnel counterfeit drugs into legitimate sales channels.
Pharmaceutical can take a number of steps to proactively respond to the hybrid risks of counterfeiting, theft, and diversion. Understanding areas where price differentials, or rapid changes in prices, intersect with organized criminal groups, open trading environments, and scarcity can help companies narrow down where they should focus their efforts. Pharmaceutical companies often go to great lengths to assess their API and third-party manufacturing sites but pay less attention to distributors, who are often the weak link for theft and diversion schemes. Identifying every business partner involved in supply and distribution chains in those countries – and thoroughly vetting them with audits and other assessments – can further reduce the risk. As pharmaceutical firms expand into countries in Asia, Eastern Europe, and South America where they are less familiar with the local operating environment, this vetting is even more crucial.