Everything is Online

How You, Too, Can Become an E-pharma Affiliate

By Erin Siegal

In a YouTube video clip dated May 19, 2008, Shahab Akhavan stares straight into a webcam, unsmiling. He’s wearing glasses and his dark hair is neatly covered by a Yankees cap.

Although the young man’s lips have been moving from the video’s start, the sound kicks in almost four seconds later. Akhavan’s voice is slightly accented.

“I just ordered some medication from this online pharmacy,” he says, slowly.

“I was surprised at how soon I received it. I recommend it… for the people…”

His voice trails off and the clip abruptly ends.

According to his Facebook and LinkedIn profiles, Akhavan is a 26-year-old Jewish Iranian-American living in Los Angeles, California.

He’s gone on a birthright tour to Israel and likes hiking on the weekends. What these online profiles don’t say is that Akhavan is an online entrepreneur who puts up Web sites that sell a range of goods and services, including prescription-only drugs.

Posting videos on YouTube is one way some Web entrepreneurs like Akhavan market products and drive traffic to their sites. Akhavan is the registered owner of both anti-anxiety-pills.net and online-discount-pharmacy1.com, two sites that advertise the sale of prescription drugs without the need for a face-to-face consultation with a physician.

A search on DomainTools, a database of Web site name registrations, shows he owns 25 other domains, including bestcreditrates.net, a credit card rate comparison site, and loansandinsurances.com, which provides debt settlement, credit repair and loan help.

Akhavan declined and then would not respond to repeated requests for an interview by phone, email and Facebook message. But he has left digital footprints that attest to his various business activities. Over the past year, for example, he has posted some 50 YouTube clips using the monikers “Shahab6” and “Bijan814.”

About a quarter of these videos were related to online pharmacies and buying drugs online. Akhavan's clips, which he both starred in and narrated, direct users to his sites by listing the pharmacy’s URL within the text of each video’s description. Drugs mentioned include Soma and Tramadol, painkillers available in the United States via prescription only.

Advertisements for prescription drugs are subject to federal oversight via the Food and Drug Administration’s Prescription Drug Marketing Act of 1987. By regulating how drugs are marketed, the FDA is supposed to protect consumers from “counterfeit, adulterated, misbranded, sub-potent, or expired drugs.”

John Mack, the editor of Pharma Marketing News/Pharma Marketing Blog, said that placing promotional videos on YouTube skirts regulations.

“It's a good way,” he said, “of keeping ads that violate FDA regulations alive.”

‘Rogue’ Site Affiliates

Shahab Akhavan’s sites, anti-anxiety-pills.net and online-discount-pharmacy1.com, are both e-pharma affiliate sites. Their role is to funnel retail orders from customers to larger Internet pharmacies.

In Akhavan’s case, these larger online pharmacies are RxPayouts.com and RxCash.bz, which LegitScript, a widely known online pharmacy verification Web site, describes as “rogue” sites. LegitScript states that so-called "rogue" sites violate or appear to violate U.S. laws, use “fraudulent or deceptive business practices," or do not follow the accepted standards of safety and pharmacy practice established by the National Association of Boards of Pharmacy.

In December 2008, LegitScript worked with domain name registries to shut down 500 rogue pharmacy websites. And RxPayouts may be next.

“RxPayouts is one of the largest rogue affiliate networks in the world,” said John Horton, president of LegitScript. “And RxCash.biz is in the top ten of about 150 to 175 affiliate networks.”

Horton estimated that around 50,000 rogue online pharmacies like Akhavan’s are operating at any given time and that affiliate sites make up roughly 98 percent of all Internet pharmacies.

“Most of the affiliate site owners understand what’s going on,” he said. “But because they’re not the ones actually handling or shipping the drugs, they pretend it absolves them of responsibility.”

By becoming affiliates, webmasters like Akhavan are afforded a relatively quick and simple way to cash in on a slice of the e-pharma cyber-pie.

Affiliates sites operate by collecting commissions on the sale and delivery of drugs, which are activities performed by the larger sites. No prior knowledge of pharmacology, medicine or doctors is needed. No identification is required. No address is needed.

“All you have to do is complete our very simple Registration Form and you can start making money right away!” is the summary provided on RxCash.biz’s FAQ’s page.

According to the online FAQ’s of both RxPayouts.com and RxCash.biz, affiliates set their own prices, create their own shipping charges and utilize a ready-made infrastructure including credit card processing, pharmacies and doctors, and around-the-clock customer support. Both sites entice potential affiliates with a possible 60 percent revenue share.

A working email address is all that’s needed to set up shop as an affiliate, which the Behind Online Pharma investigative team did. Within 24 hours, we were approved to become an affiliate of both RxPayouts.com and RxCash.biz. The only information we were asked to supply was a name, email address and geographic location.

The approval email sent from RxPayouts.com contained directions on how to log into the larger site’s “Admin Interface” to create a potential backend of a new e-pharma affiliate site. Instructions were given on how to set up the business, and templates were available for download. The process of registering and starting up as an affiliate can be done in less than a day.

Dima, who did not provide a last name, is the Cyprus-based affiliate manager for RxCash.biz. Via Skype, he explained that he personally approves new affiliates.

“I have affiliates making close to $10,000 a month, and I have some not making even a hundred,” he said. “It depends how much and how hard you work.”

"Your ignorance is not going to save you. It’s going to condemn you.”

No Prescription Needed

On the front page of Akhavan’s site, online-discount-pharmacy1.com, one line is on prominent display: “No prior prescription needed.”

Along the side of the page, a long list contains both prescription and nonprescription drugs available for purchase.

To buy medication, customers use a standard online shopping cart. They then click through to a “secure transaction server” hosted by cartadmin.com and are asked to enter a credit card number and address.

Customers are also asked to fill out a brief medical query, which asks questions such as whether the medication has been taken before, whether the customer has had a physical exam within the last 12 months, and if the customer is being treated for any other condition. According to the online-discount-pharmacy1.com customer service team, the questionnaire goes on to be reviewed by a “licensed U.S. Doctor.”

But when asked about the doctors, customer service representative Holly refused to identify any. Daniel, another rep, said that a “board” licenses the site’s anonymous doctors yet he wouldn’t specify which board. Marcus, a third rep, said that the FDA licenses the doctors. Additionally, none of the reps would name which “U.S. pharmacies” actually filled orders placed through the site.

“There are no doctors,” countered LegitScript’s Horton. “Most affiliates don’t even know where the drugs are coming from."

Jon Praed, an attorney specializing in cybercrime, says that affiliate owners like Akhavan can and should be held responsible for their role in promoting the business of rogue online pharmacies. If the larger sites required all affiliate owners to verify their identities, he said, there would be a clearer path to accountability.

“Affiliates certainly can be held responsible for the acts of the larger pharmacies,” Praed said. “If they [larger sites] can’t do it, their agents [affiliates] can’t be allowed to do it. It’s negligence by proxy.”

He added that even if affiliate owners don’t fully understand the workings of the sites they’re linked to, they can still be held legally liable for willful recklessness, negligent enablement and flat-out criminal responsibility.

“The question’s not what they know, but what they should know,” said Praed. “Your ignorance is not going to save you. It’s going to condemn you.”

It’s unclear just how much Shahab Akhavan knows about the larger Web sites that provide his affiliate income.

In one of his YouTube videos, dated April 22, 2008, he explained the difference between legit and illegitimate methods of obtaining prescription drugs.

“There are people who import drugs illegally from India and Costa Rica, either through drop shipping to the U.S. or through bulk, and pick up the package and distribute them,” he explained. “That is illegal.”

He went on to explain that buying Schedule III, IV and V drugs online if one has  a “medical record, doctor’s consultation on the phone, and follow up” is legal.

Yet Dima, the affiliate manager for the site fulfilling orders from Akhavan’s anti-anxiety-pills.net, says those purchasing drugs online never communicate with a physician.

“In this business, customers don’t ask to see the doctor,” he said. “Everything is online.”