Sample Report

Transcription

Sample Report

 LegitScript | Internet Pharmacy Verification
818 SW 3rd Ave. #353, Portland, Oregon 97204
877-534-4879 (tel), 503-914-0308 (fax)
[email protected]
Investigative Report
BestKusuri/BestKenko
August 2015
818 SW 3rd Ave. #353 | Portland, Oregon 97204 | 877 534 4879 | legitscript.com
Contents 1.0 BestKusuri/BestKenko — Illegal Drug Sales TargeGng the Japanese Market ...................3 2.0 Japanese RegulaGon of Online Drug Sales and Personal ImportaGon .............................7 3.0 Origin and Ownership of the BestKusuri/BestKenko Network .........................................9 4.0 Singapore Dispensing Center and Drug Sourcing .............................................................14 4.1 Scanpro Paciﬁc Pte. Ltd. ..............................................................................................14 4.2 Vista Pharma ...............................................................................................................15 4.3 Alps Pharmacy aka Anam Trading Pte. Ltd. aka Anam Pharmacy ................................16 4.4 SAVA Global .................................................................................................................17 4.5 VaijanG Pharmacy ........................................................................................................18 4.6 AdverGsed Medicines .................................................................................................20 5.0 Domain Name RegistraGon and Website OperaGon ........................................................23 6.0 Website Content ..............................................................................................................24 7.0 Payment and Merchant Accounts ....................................................................................27 8.0 Conclusion ........................................................................................................................29
Appendix A: BestKenko Domain Name Workup (DNW) Appendix B: Singapore Licensed Pharmacies 2
LegitScript Research Report | BestKusuri/BestKenko | July 2015
1.0 BestKusuri/BestKenko — Illegal Drug Sales Targe<ng the Japanese Market This report describes the operations of the largest rogue Internet pharmacy network
targeting Japan: the “BestKenko” (previously, “BestKusuri”) group of websites. It outlines the
history of the network, describes the nature of its legal violations, and identifies the principal
individuals who run the network — Singapore-based Mark RADFORD and Robin
SCRIMGEOUR, Japan-based partner Joel DEVIDAL, and India-based drug suppliers SAVA
Global and Vaijanti Pharma — and their shell companies.
As background, Japan’s pharmaceutical market is the second-largest in the world,
following the United States. The size of the Japanese market makes it an attractive target market
for sellers and suppliers of unregulated prescription drugs. The majority of sellers are affiliates of
organized, illegal Internet pharmacy affiliate networks whose owners, affiliates, and drug
suppliers illegally import unregulated drugs into Japan in violation of Japanese health and
pharmacy policies and laws.
In Japan, the Japanese Ministry of Health, Labor and Welfare (MHLW) is the national
agency responsible for protecting and promoting the health and welfare of Japanese citizens.
Japan has some of the strictest drug safety laws in the world, and LegitScript has been retained
by MHLW to identify and expedite the shutdown of websites that facilitate illegal Internet drug
sales. LegitScript’s activities to curtail illegal online drug sales on behalf of MHLW include
representation of MHLW directives and domain name suspension requests to the hundreds of
domain name registrars around the world that operate under accreditation by the Internet
Corporation for Assigned Names and Numbers (ICANN).
In 2013, LegitScript reviewed 2,345 individual Japanese-language search results that
referred to websites that marketed prescription drugs to Japanese consumers.1 LegitScript
1
http://www.legitscript.com/download/Japanese%20Threat%20Assessment%202013%20Update%20ENGLISH
%20Version.pdf
3
research showed that less than 0.1 percent of these 2,345 search results promoted or linked to
Internet pharmacies that operate in compliance with MHLW policies and regulations. In other
words, more than 99.9 percent of the search results referred to Internet pharmacies that operated
in compliance with MHLW policies and regulations. LegitScript found that 44 percent of these
illegal pharmacy websites were operated by only three distinct pharmacy networks. LegitScript
refers to these three networks, listed in order of size, as:
•
BestKenko, previously known as BestKusuri, based in Singapore;
•
Roy Union, based in China; and
•
RxCash.biz, with network management based in Israel and customer service operations
located in Ukraine.
BestKenko, formerly known as the BestKusuri network, claims to be Japan’s largest
health-related Internet shopping network, and LegitScript’s analysis indicates that the network is
the largest illegal online pharmacy network targeting Japan. BestKenko website content is
written in the Japanese language and generally, the websites use Internet traffic control
technologies based on Internet Protocol (IP) addresses to restrict display of the pharmacy content
to browsers that use a Japanese IP address, in a process known as geo-targeting.
In 2012, LegitScript worked with domain name registrars to suspend the domain name
registrations for several Internet pharmacy websites operating under the flagship “BestKusuri”
brand. This rendered the BestKusuri websites invisible to Internet users. In response, the network
changed its primary brand name to BestKenko and found new domain name registrars that would
protect BestKenko domain name registrations from suspension requests.
BestKenko sells both human and pet prescription medicines that include a large number
of unapproved drugs — that is, drugs that are not approved and regulated by the Japanese
government for safety and authenticity. BestKenko aggressively operates Internet pharmacies in
4
violation of Japanese laws and regulations by selling unapproved drugs without a prescription2
that are shipped directly to Japanese consumers from a dispensing pharmacy and fulfillment
center in Singapore. Every product page (including those with supplements) shows the following
image with text in the Japanese language that among other claims states, “All the products can be
delivered anywhere in the country without prescription.”
Fig 1: BestKenko Service Guarantees
!
LegitScript continues to monitor BestKenko Internet activity for the Japanese MHLW.
BestKenko currently operates hundreds of management-owned and affiliate pharmacy and
referral websites and continually registers new domain names to maintain and increase its
Internet footprint. LegitScript’s database contains a list of more than 800 active BestKenko
pharmacy and affiliate referral websites. The majority of these websites redirect customer orders
to a very small number of flagship order-processing websites, that include the BestKenko
flagship Internet pharmacy website bestkenko.com, a sister company “Medicine Express”3
flagship website, kusuriexpress.com, the veterinary “PetKusuri” flagship website, petkusuri.com,
and a second veterinary brand flagship, genkipet.co.
The Japanese MHLW has authorized LegitScript to pursue suspension of BestKenko
domain name registrations and online merchant processing services as a way to curtail the
activity of the network. Despite these efforts, the network has found “safe haven” with a few
2
See, for example, the no prescription statement at http://www.bestkenko.com/products/
%E3%83%91%E3%83%AD%E3%82%AD%E3%82%BB%E3%83%81%E3%83%B320mg.html
3
5
http://besutokenkou001.zouri.jp/kaisyagauyou.html
registrars, including Tucows in Canada, that refuse to suspend the domain name registrations
used by BestKenko for its flagship Internet pharmacy websites. These same few registrars allow
the network to register new domain names using a variety of business names and anonymous
registration services. The BestKenko practice of using a variety of registered and non-registered
business names and anonymous postal mail services to hide the network ownership, supplier
structure, and their true operational locations makes shutdown of the network operations
additionally difficult.
The remainder of this report describes the illegal nature of the BestKenko operations, the
network owners, investors and affiliates, the drug suppliers and dispensing pharmacies,
LegitScript’s recent activities in shutting down the merchant account used by the network for
online payment processing, and the network’s ongoing domain name registration and active
website operations. 6
2.0 Japanese Regula<on of Online Drug Sales and Personal Importa<on Japanese policies and laws regarding Internet marketing are stringent: as a general rule,
prescription medicines cannot be sold over the Internet in Japan and no licensed Japanese
pharmacy is permitted to sell prescription drugs online or to actively market unapproved drugs to
Japanese customers via the Internet. This far-reaching policy is, however, complicated by a legal
loophole, or exception, that permits personal importation of prescription drugs in exceedingly
narrow circumstances. The exception is limited, and is written to permit a small degree of
prescription drug importation, and is permitted only if the Internet pharmacy website does not
advertise drugs and display drug images that are unapproved by Japanese laws and regulations.
To fully comply with guidance issued by the MHLW, the website sales activities must be
“passive” — that is, the website cannot actively attract Japanese customers by advertising
unapproved drugs by drug specific text or images, for this exception to apply; otherwise, the
prescription drug importation exception is not allowed. This drug importation exception in
Japanese regulation is presumably intended for the purchase of drugs from a pharmacy that is
known to be a safe and appropriately licensed pharmacy in the country in which it operates ––
for example, a licensed, safe pharmacy in the US. The reality is that far less than 1 percent of
websites that target Japanese consumers with drug images and text and that facilitate the
importation of drugs into Japan actually adhere to the importation exception and other health and
pharmacy policies and regulations issued by the MHLW. None of BestKenko’s websites come
close to complying.
None of the BestKenko websites that market unapproved medicines to Japanese
customers adhere to the narrow nature of the personal drug importation exception, although the
websites claim –– inaccurately –– that their websites are legal because “prescription drug
importation is permitted in Japan.” This is an inaccurate interpretation of the importation
exception and, in all other respects, a violation of the Japanese prohibition of active Internet
marketing and sale of unapproved drugs. Additionally, BestKenko websites that actively market
7
and sell unapproved drugs to Japanese consumers do not dispense drugs from legitimate,
licensed pharmacies in the US or other countries, despite the website text and images that claim
the drugs they sell are approved drugs that are dispensed from legitimate, licensed pharmacies.
The BestKenko “Beginners Guide,”4 which is made available to Internet users as a top
menu choice on the bestkenko.com website, disavows any responsibility for ensuring that
prescription drugs sold by the network can be legally purchased by Japanese consumers. The
guide claims that the sole responsibility for a legal purchase lies with the end consumer, who
must buy the drugs under a Japanese personal importation exception law. BestKenko
inaccurately represents that this personal exemption allows Japanese consumers to import drugs
from other countries, and in the case of BestKenko, the drugs are sourced in India5 and dispensed
from a fulfillment center in Singapore.6 BestKenko’s description of the Japanese personal drug
import exception is an invalid interpretation of Japanese law. (Note: BestKenko does not limit its
sales to individuals — the network offers special buyer memberships to doctors and clinics for
wholesale purchase of prescription drugs for discounted rates and statements on bestkenko.com
indicates that network has offered medicines to Japanese cosmetic clinics.)7 4
http://www.bestkenko.com/pages/初めての方へ.html
5
http://www.bestkenko.com/pages/EDのジェネリック薬の現状は？.html?submit=agree
6
http://www.bestkenko.com/pages/%E3%81%94%E5%88%A9%E7%94%A8%E3%82%AC
%E3%82%A4%E3%83%89.html?submit=agree
7
8
http://www.bestkenko.com/pages/doctors.html/?submit=agree
3.0 Origin and Ownership of the BestKusuri/BestKenko Network The BestKenko network was founded in 2009 using the branding BestKusuri and
PetKusuri. The network changed its human medicines group name to BestKenko after
LegitScript successfully shut down the flagship and namesake Internet pharmacy websites in
2012. The network retained the animal pet medication group name of PetKusuri, but collectively
the network is referred to in the remainder of this report as BestKenko or BestKusuri/BestKenko.
Sometime after the websites using the “BestKusuri” name brand were shut down, the
BestKenko network added a “sister” human medicines group, Medicine Express, and a second
pet medicine group, GenkiPet. Collectively, these Internet brands are part of the BestKenko
network, which operates under the umbrella of a Singapore private investment firm, Rajah Blue
Holdings Pte. Ltd. Rajah Blue maintains a portfolio of its private investment businesses, which
include a Singapore business named Scanpro Pacific Pte. Ltd. Scanpro Pacific and Rajah Blue
directors operate the Singapore distribution center that stores and ships BestKenko drugs.
Another Rajah Blue business, Ichikado, Ltd., owns the BestKenko brand names, and the
directors of Rajah Blue work with silent partners or investors to operate the BestKenko affiliate
network and drug supply chain. In July 2015, a Rajah Blue director registered a new company,
Sakura United Ltd, in the UK and that name now appears on some versions of bestkenko.com.
The medicines sold by BestKenko are supplied by one or more entities in India, including SAVA
Global, a contract drug manufacturer and drug import/export company and, more recently in
2015, an India drug distributor known as Vaijanti Pharmacy, which is affiliated with a group of
India doctors who operate a small hospital in India.
This section describes the individuals who own and manage the BestKenko affiliate
marketing, sales, dispensing, and shipping operations. The following section describes the
network supply and distribution network that is controlled in India by SAVA Global and its
9
subsidiary SAVA Intertrade FZE located in the United Arab Emirates (UAE) and by India-based
Vaijanti Pharmacy and pharmacist-in-charge Amruta Kenge Desphande.
BestKusuri was established as a three-party equal-share ownership8 between the
Singapore-based distribution company Scanpro Pacific Pte. Ltd. (scanpropacific.com and
scanpro.co.sg) and the individuals Joel DEVIDAL (jooto.com and zaporo.com) and Mark
RADFORD (Facebook, LinkedIn, Knowesis). DEVIDAL and RADFORD partnered in the
international marketing company DialUsNow,9 which was registered as DialusNow, Ltd.10 in the
UK and simultaneously registered in Singapore as DialUsNow Pte. Ltd.11 The DEVIDAL and
RADFORD partnership includes US real estate investments in Florida and possibly Michigan,
under the Florida registered company Sakusen Investments, LLC.12
Partners DEVIDAL and RADFORD are Internet marketing, technology, and
telecommunication entrepreneurs who continually form new companies that target the Japanese
market. Their customers are both the end-consumers who purchase the medicines sold by the
BestKenko network and other entrepreneurial individuals or businesses who want to do business
in Japan. DEVIDAL and RADFORD operate using a variety of dba names, including
Dialusnow13 (dialusnow.com — offline) and Onenrg (onenrg.com14, 15 — offline). RADFORD
also does business as Bushido Enterprises (bushido-enterprises.com16 — offline), a dba name
that was displayed on bestkenko.com, until late July 2015. On July 20, 2015, Robin Macdiarmid
Campbell SCRIMGEOUR (Facebook, LinkedIn), a director of Rajah Blue, registered Sakura
8
http://companycheck.co.uk/director/913650329/JOEL--DEVIDAL/group-structure
9 Archive
domain name registrations - Bushido Enterprises - Radford
10
http://companycheck.co.uk/company/06826918/DIALUSNOW-LTD/directors-secretaries
11
Singapore Government E-Service Directory of Registered Entities
12
State of Florida (sunbiz.org) - Sakusen Investments, LLC
13
http://www.petkusuri.com/pages/Shipping%20&%20Returns.html
14
https://web.archive.org/web/20091222081435/http://www.onenrg.com/
15
https://web.archive.org/web/20130803114718/http://kamome.cn/docs/18388
16 Archive
10
domain name registrations - Bushido Enterprises - Radford
United Ltd.,17 in the UK. This new business name has replaced Bushido Enterprises on
bestkenko.com,18 as shown in the screenshots of bestkenko.com below.
Fig 2: Screenshots of bestkenko.com, Trade and Owner Name Display page
bestkenko.com - July 16, 2015
bestkenko.com - July 28, 2015
Affiliate referral websites that link to bestkenko.com may continue to refer to Bushido
Enterprises.19
Scanpro Pacific and, by extension, the BestKenko network operate under the umbrella of
Rajah Blue Holdings Pte. Ltd. aka Rajah Blue Capital (rajahblue.com), a Singapore private
portfolio investment business that identifies Scanpro Pacific as one of its portfolio companies.
Additionally, Ichikado, UK,20 and Ichikado, Hong Kong, identified in PetKusuri terms of
operation and as the owner of the PetKusuri trademarks,21 are controlled by Rajah Blue director
Robin SCRIMGEOUR, who is also the registered director of Sakura United, Ltd., shown in the
previous screenshots of bestkenko.com.
17
http://www.bestkenko.com/pages/%E7%89%B9%E5%AE%9A%E5%95%86%E5%8F%96%E5%BC
%95%E6%B3%95%E3%81%AB%E5%9F%BA%E3%81%A5%E3%81%8F%E8%A1%A8%E7%A4%BA.html
11
18
http://www.bestkenko.com/pages/特定商取引法に基づく表示.html
19
See, for example, www.beyondareasonabledoubtmovie.com.
20
http://companycheck.co.uk/company/08140548/ICHIKADO-LTD/directors-secretaries
21
http://www.petkusuri.com/pages/Terms%20of%20Use.html
SCRIMGEOUR’s registration of Ichikado, UK is significant: several pages on the
PetKusuri website, including the Japanese-language version of the Terms page, identify the
owning company as Ichikado, UK and the dispensing pharmacy as Alps Pharmacy.22 Archive
records show that the BestKusuri/BestKenko network has used the PetKusuri merchant name to
process online credit card transactions for both BestKusuri/BestKenko and PetKusuri websites
since 2010.23 In other words, the PetKusuri merchant account has been in continuous use for
online credit card purchases for both pet and human medications sold by the BestKusuri/
BestKenko network since 2010 or earlier, and Ichikado, UK controls the PetKusuri brand. (Note
that in July 2015, LegitScript, working with Visa, requested suspension of the PetKusuri credit
card merchant account sponsored by banks.. More information about the network’s payment
processing and merchant accounts is provided later in this report.)
LegitScript believes that DEVIDAL, RADFORD, SCRIMGEOUR, and their business
partners have used the offshore and shelf company services business Offshore Incorporations HK
Limited (offshore-inc.com and oilglobal.com) to incorporate and register their various dba
business names in the British Virgin Islands (BVI), Hong Kong, Mauritius, UK, and US
jurisdictions.24 The loss of the PetKusuri Visa merchant account was temporary — the business
obtained another merchant account, which at the time of this writing LegitScript is in the process
of shutting down — and over 800 BestKenko pharmacy and referral websites remain online and
appear to continue to accept customer orders at the time of this report.
RADFORD’s and SCRIMGEOUR’s LinkedIn profiles are shown on the following page.
22
https://www.petkusuri.com/pages/%E7%89%B9%E5%AE%9A%E5%95%86%E5%8F%96%E5%BC
%95%E6%B3%95%E3%81%AB%E5%9F%BA%E3%81%A5%E3%81%8F%E8%A1%A8%E7%A4%BA.html
12
23
https://web.archive.org/web/20100324175558/http://www.petkusuri.com/manualBK/
24
http://www.oilglobal.com/jurisdictions
Fig 3: Mark Radford LinkedIn profile
Fig 4: Robin Scrimgeour LinkedIn profile
!
!
13
4.0 Singapore Dispensing Center and Drug Sourcing Drugs sold by the BestKenko network are supplied by two companies in India, SAVA
Global (savaglobal.com) and Vaijanti Pharmacy (vaijantipharma.com — offline). The drugs are
shipped from India to Sharjah Airport International Free Zone (SAIF Zone) in the UAE. From
there, the drugs are shipped, warehoused, and dispensed from a fulfillment center in Singapore to
customers in Japan. BestKenko claims that its Singapore distribution center is certified by the
Singapore government and that it supplies more than 2,000 different drugs where the dispensing
operations are supervised by a staff of 12 pharmacists.25 (That this is almost certainly untrue is
underscored by the fact that the network sells drugs unapproved in both Japan and in Singapore,
such as Kamagra.) A YouTube video posted on the PetKusuri flagship website, petkusuri.com,
shows outgoing orders labeled as shipping to Singapore.
4.1
Scanpro Pacific Pte. Ltd.
The BestKenko Singapore distribution and shipping company is identified on the
PetKusuri websites as Scanpro Pacific Pte. Ltd.26 Scanpro Pacific
(scanpropacific.com) is a Singapore company that describes it business as a multi-line
distributor and retailer of industrial and consumable products, including
pharmaceuticals. Scanpro is a portfolio company of the private investment firm Rajah
Blue Holdings Pte. Ltd. (rajahblue.com). LegitScript reviewed Singapore government
records for licensed pharmacies, licensed pharmacists, and licensed medicine
importers and wholesalers, and did not find records that indicate Scanpro Pacific is
licensed in Singapore to operate a pharmacy or drug import and export business.27 A
YouTube video posted on the PetKusuri flagship website, petkusuri.com, shows the
25
http://www.bestkenko.com/pages/%E3%81%94%E5%88%A9%E7%94%A8%E3%82%AC
%E3%82%A4%E3%83%89.html
26
http://www.petkusuri.com/pages/Shipping%20&%20Returns.html
27
http://www.hsa.gov.sg/content/hsa/en/Health_Products_Regulation/
Info_search_for_Health_Products_and_Services.html
14
distribution center packaging process with outgoing orders placed in a mail bag
labeled “Singapore.”28
4.2
Vista Pharma
Some BestKenko domain name registrations provide a clue as to the licensed
Singapore pharmacies and pharmacists that the BestKenko network claims to employ.
Vista Pharma, a BestKenko domain registrant, provides a postal street address at “91
Alps Avenue,” in Singapore. This address is part of a Federal Express mail center
located just outside the Singapore airport.29
A search of Singapore registered businesses did not return any records for Vista
Pharma. However, an address search of pharmacies licensed by the Singapore
government30 identified two pharmacies, Alps Pharmacy and WestMead Pharmacy, at
“91 Alps Avenue.” Vista Pharma and Alps Pharmacy have the same street and box
address, “91 Alps Avenue, #03-01,” and LegitScript believes that Vista Pharma is a
another dba name used by SAVA Global to do business as the Singapore licensed
pharmacy, Alps Pharmacy. Westmead Pharmacy (westmeadpharmacy.com) describes
itself as a fulfillment center pharmacy, but uses a different post office box than Vista
Pharma and Alps Pharmacy, “91 Alps Avenue, #03-10.” The managing pharmacist of
Westmead Pharmacy is Foo Ah Lan JOYCE,31 whose Singapore pharmacist license
shows that JOYCE is employed by the Singapore chain store pharmacy Guardian
Health & Beauty (guardian.com.sg). Review of the Guardian website shows a fleeting
entry on their store locator map for 91 Alps Avenue.32 15
28
https://www.youtube.com/watch?v=OIjIkvYdSVY
29
http://www.fedex.com/sg/dropoff/
30
Search for “Alps”: http://eservice.hsa.gov.sg/prism/common/enquirepublic/SearchPharmacy.do?action=load
31
Search for “Foo Ah Lan Joyce”: https://prs.moh.gov.sg/prs/internet/profSearch/main.action?hpe=SPC
32
Search map for close-up of the Singapore airport: http://www.guardian.com.sg/store-finder
4.3
Alps Pharmacy aka Anam Trading Pte. Ltd. aka Anam Pharmacy
Singapore business registration records33 show that Alps Pharmacy was formerly
known as Anam Trading Pte. Ltd. (Google+) aka Anam Pharmacy. Anam Pharmacy is
known by LegitScript to be a former subsidiary of SAVA Global, the India-based drug
manufacturer and import/export drug wholesaler that provides drugs and fulfillment
services to several unapproved and rogue online pharmacy networks.34 In a patent
infringement lawsuit in the US, Bayer identified Anam Pharmacy as a dispensing
pharmacy of counterfeit or trademark-infringing drugs sold by Canadian mail-order
pharmacies, and other named defendants included Ronin Ventures,35 a business
named used by Joel DEVIDAL and Yuko Tanaka to register one or more original
BestKusuri domain names.
Alps Pharmacy (alps-pharmacy.sg) is a fulfillment pharmacy that is known to
dispense drugs for one or more of the unapproved Canadian mail-order pharmacies,
in particular the Solaris network, which lists Alps Pharmacy as a dispensing
pharmacy on its order forms.36 Confidential sources have informed LegitScript that
Vinod JADHAV owns one of the Solaris network websites37 and that Solaris controls
and advises other Canadian mail-order pharmacies. In hidden content on the Alps
Pharmacy website, it claims that it is an approved PharmacyChecker38 foreign
pharmacy.39
33
Search for “Alps Pharmacy”: https://www.psi.gov.sg/NASApp/tmf/TMFServlet?app=RCB-BIZFILE-LOGIN-1B
34
https://blog.legitscript.com/2012/10/bestkusuri-com-japanese-rogue-pharmacy-linked-to-singapore-internet-firms/
35
http://www.law360.com/cases/4e6fa22a904343530c000004
36
See Solaris network partners pharmacies: http://www.canadapharmacyonline.com/docs/Orderform.pdf
37
16
See www.globaldrugsdirect.com.
38
https://www.legitscript.com/about/setting-the-record-straight/
39
See Google cache copies of alps-pharmacy.sg (for example, Google cache July 6, 2015).
In Singapore, LEE Kim Siong Peter, aka Peter LEE Kim Siong, aka Peter LEE
(LinkedIn) is licensed as the managing pharmacist of Anam Trading Pte. Ltd.40 LEE
also does business as Lindee Enterprises, a Singapore wholesale pharmaceutical
business. Another pharmacist, Lee Swan KEE, is also licensed by the Singapore
government as an Alps Pharmacy pharmacist and as a pharmacist doing business as
FP Marketing (S) Pte. Ltd. (Google+).41
An undated Singapore government spreadsheet of licensed Singapore pharmacies,
which contains entries for Alps Pharmacy and Westmead Pharmacy, is attached to this
report as Appendix B.
4.4
SAVA Global
Vinod JADHAV (Facebook, LinkedIn, Yatedo) is the founder of SAVA Global
(savaglobal.com), which is also known as SAVA Healthcare, Ltd. and SAVA Group.42
SAVA Global is based in India and operates drug and dietary supplement
manufacturing and import/export subsidiaries or partnerships in India, Asia, Russia,
and the US. In Singapore, SAVA Global does business as SAVA Medica (Singapore)
Pte. Ltd.,43 and the pet medicines labeled “SAVAVET” in the petkusuri.com video are
produced by SAVAVET (savavet.com), another SAVA Global subsidiary.
Although SAVA Global claims to be a drug manufacturer, further research indicates
that the company primarily operates as a contract manufacturer that uses low-cost
third-party manufacturers to produce the generic and research drugs and dietary
supplements SAVA provides to its partner businesses. SAVA Global operates its
foreign subsidiaries in partnership with other businesses such as Alps Pharmacy in
17
40
Search for “Alps Pharmacy”: https://www.psi.gov.sg/NASApp/tmf/TMFServlet?app=RCB-BIZFILE-LOGIN-1B
41
https://prs.moh.gov.sg/prs/internet/profSearch/main.action?hpe=SPC
42
http://indiankanoon.org/doc/116902325/?type=print
43
http://savaglobal.com/global-offices.html
http://savaglobal.com
Singapore, the mail-order Canadian pharmacy known to LegitScript as Solaris, and
the US-based dietary supplement business, Savesta (savesta.com), which is a joint
venture with Avesthagen, India (avesthagen.com), the owner of the US manufacturing
facility.
Additional indication of SAVA Global’s association with the BestKenko network as a
supplier, seller, and network owner is shown in several BestKenko domain name
registrations. The SAVA Global domain name registrations include:
•
domain name registrations by registrant Vista Pharma using the Alps
Pharmacy aka Anam Pharmacy postal address in Singapore.
•
historical, non-anonymous domain name registrations that identify the
registrant as Anagha Pharma, a SAVA Global subsidiary.44 These domain
names include the flagship Internet pharmacy websites bestkenko.com,
kusuriexpress.com, and petkusuri.com. For more information, see the
“Explanatory Notes” in Appendix A: BestKenko Domain Name Workup.
•
current and historical domain name registrations that use either a Sharjah
Airport International Free Zone (SAIF) in UAE postal address, or the name of
the SAVA Global transshipment center, SAVA Intertrade FZE, for example
vistapharma.biz.
4.5
Vaijanti Pharmacy
In early 2015, a new domain name registrant, Vaijanti Pharmacy, appeared in
BestKenko domain name registrations. In response to LegitScript monitoring and
domain name suspension activities on behalf of Japan’s MHLW, LegitScript was
contacted by a Canadian attorney representing Vaijanti Pharmacy, the India company
that claims to be the current licensed pharmacy dispensing drugs for the BestKenko
44
18
http://www.savaglobal.com/awards-accolades.html
network. The India pharmacy license and the pharmacist-in-charge license for
Vaijanti Pharmacy is issued to Mrs. Amruta Kapil DESHPANDE nee Amruta Krishna
KENGE. Although Vaijanti Pharmacy is licensed in India, the business is not itself a
registered India corporation. LegitScript research indicates that Vaijanti Pharmacy is
not a traditional retail pharmacy in the sense that it serves individual patients, but
rather it operates as an India stockist,45 a specific type of warehouse and export
clearing and forwarding agent in India that is used by pharmaceutical manufacturers
to handle drug distribution.
Amruta DESHPANDE and her husband, Kapil Jayant DESHPANDE,46 use a
common telephone number (+91.9850146471 or, alternatively, 9850146471). This
telephone number is associated with the Vaijanti stockist business,47 and beginning in
2015, it is also used in BestKenko domain name registrations by Vaijanti Pharmacy,
India or Vista Pharma, Singapore. Prior to 2015, Vista Pharma had been associated
with SAVA Global. The relationship, if any, between Vaijanti Pharmacy and SAVA
Global is unknown to LegitScript at the time of this report.
Vaijanti Pharmacy shares a postal address and business name48 with the registered
India business Ekdant Enterprises Pvt. Ltd. The five directors of Ekdant are doctors,
serving on the board of CIIGMA Institute of Medical Sciences Pvt. Ltd.
(ciigmahospital.org), a small hospital in Pune, India.49 The Ekdant directors are
Mandar Suresh Abhyankar, Pushpa Ravindra Kodlikeri, Vaishakh Pralhad Palsodkar,
Unmesh Vidyadhar Takalkar, and Mrs. Manisha Unmesh Takalkar. It is not known at
45
https://www.dolcera.com/wiki/index.php?title=Indian_Pharma_Industry_-_Distribution_
%26_Sales_Force_Structure
46
http://www.consumercomplaints.in/profile-1032134
47
http://aeranlab.com/NEW%20STOCKIST%20LIST.pdf
48
https://www.zaubacorp.com/company/EKDANT-ENTERPRISES-PRIVATE-LIMITED/
U74999PN2012PTC144010
49
19
http://www.ciigmahospital.org/chief_con.html
the time of this report whether Ekdant Enterprises operates as an agent for CIIGMA
hospital, or as a subsidiary of SAVA Global, or as a partner or owner of Vaijanti
Pharmacy.
4.6
Advertised Medicines
BestKenko claims the network sells more than 2,000 different drugs in the following
condition or treatment categories:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Alzheimer’s
Anti-aging
Antibiotics
Beauty and skin treatments
Contraceptives
Depression/Anxiety
Diabetic
Diet
Hair growth and care
High blood pressure
Himalayan dietary supplements
Hormones
Insomnia
Pain analgesics
Sexual dysfunction and enhancement
Smoking cessation
The flagship bestkenko.com website displays a large number of pharmaceutical,
veterinary, and dietary supplement company logos.50 The display includes
BestKenko’s own generic brand logo, SAVA Global brand logo, and, inexplicably, the
logo for the UK’s Medicines and Healthcare Products Regulatory Agency (MHRA).
BestKenko claims that the drugs it sells are drugs from regulated and reputable drug
manufacturers. However, some of the human and pet medicines include BestKenko
and SAVA Global brand versions of generic drugs. The BestKenko and SAVA brand
50
20
http://www.bestkenko.com/brands/
drugs are not known to be approved by health authorities in Japan, Singapore, or
India.
The integrity of the drug supply chain is also unknown. BestKenko’s own description
of its supply chain, and additional LegitScript research, indicate that the drugs
sourced in India are processed through SAVA Global and Vaijanti Pharmacy
intermediary warehouses in India and the UAE, and then shipped to the Scanpro
fulfillment center in Singapore, before the drugs are ultimately sold to Japanese
customers.
The table below lists the advertised manufacturers and suppliers that are displayed on
the “Brands” page of bestkenko.com.
BestKenko Advertised Drug Manufacturers and Suppliers
Abbott Laboratories
F. Hoffmann-La Roche AG,
Switzerland
Pierre Fabre Laboratories
AFT Pharmaceuticals,
Australia and New Zealand
FDC Pvt. Ltd., India
Q-Med, a Galderma company,
Switzerland
Ajanta, India
Glenmark
RPG Life
Akums Drugs &
Pharmaceuticals, Ltd.
Hisamitsu Pharmaceutical Co., Inc., Sava Healthcare, Sava Medical,
Japan
India
Albert David Ltd., India
Ind-Swift Limited
Schering Plough
Albion
Indi Pharma
Source Naturals
Allergan
Infinity Industries
Sun Pharma/Ranbaxy, India
Alums, UK
Intas
T.O.Chemicals
Astrazeneca
Leading Edge Health and Leading
Edge Herbal, US and UK
Taisho Pharmaceutical Co.,
Ltd., Japan
Aventis
Lundbeck
Takeda, Japan
BestKenko
Lupin Pharmaceuticals, Inc.
The Himalaya Drug Company,
India
Bexmico Pharmaceuticals,
India
Macleods Pharmaceuticals Pvt Ltd. UCB, S.A., Belgium
Boehringer Ingelheim GmbH, Meda Pharmaceuticals, Meda AB,
Germany
Sweden
Daiichi Sankyo Healthcare
Company, Japan
21
Unichem Laboratories, Ltd.,
India
Medicines and Healthcare Products
Unicure
Regulatory Agency (MHRA), UK
Eli Lilly & Company, USA
Merck Sharp & Dohme Corp., a
subsidiary of Merck & Co., Inc.,
USA
USV Ltd., India
Em Cure
Merial Sanofi, France
Win Medicare Pft., Ltd., India
Envy Medical Inc.
Micro Labs Ltd., India
Windlas BioTech Pvt. Ltd.,
India
EyeFive, US
Novo Nordisk, Denmark
Wyeth, now part of Pfizer, US
JAGSONPAL pharmaceuticals OLIC (Thailand) Limited
22
Zydus Pharmaceuticals (USA),
Inc.
5.0 Domain Name Registra<on and Website Opera<on The majority of BestKenko domain name registrations are anonymous. The small number
of non-anonymous domain registrations, along with references on the pet medication websites to
a Singapore distribution center managed by Scanpro Pacific and similar reference on those
websites to Ichikado, Ltd., the payment and trademark owner, provides information that
identifies the principal network owners or managers as Joel DEVIDAL, Mark RADFORD, and
Robin SCRIMGEOUR and their India-based partners and drug suppliers, SAVA Global and
Vaijanti Pharmacy. To a lesser extent the non-anonymous domain name registrations identify
individual affiliates or the small Internet marketing, web design, and Internet hosting firms that
support BestKenko website operations or work as BestKenko network affiliates.
Appendix A: BestKenko Domain Name Workup (DNW) contains a list of the pharmacy
and affiliate referral websites that currently make up the BestKenko network. The DNW
spreadsheet provides a list of the domain names and website URLs, the domain name registrant
names, postal addresses, telephone numbers, and email addresses, referred to as WHOIS data.
The DNW also provides information about website Internet addresses and the Internet service
providers that enable BestKenko websites to appear on the Internet.
23
6.0 Website Content The BestKenko network, as monitored by LegitScript, has over 800 active websites in
July 2015. These websites include the four flagship pharmacy “brand” websites (bestkenko.com,
kusuriexpress.com, petkusuri.com, and genikpet.co) which are the ultimate order-processing and
Internet traffic redirection targets for the hundreds of affiliate pharmacy referral websites; blog
pages and websites that LegitScript has identified and cataloged; and the anchor websites that do
not sell drugs but are used for other purposes to manage the network. BestKenko sells both
human and pet medicines. The flagship human medicine pharmacy websites are bestkenko.com
and kusuriexpress.com — bestkenko.com represents the network namesake “BestKenko” brand,
and kusuriexpress.com represents the sister brand “Medicine Express.” Both of the human
Internet pharmacy websites have a unique acceptance page that requires potential customers to
accept or decline BestKenko terms before the pharmacy catalog and images can be displayed.
This acceptance page is one method the network uses to claim it is operating in compliance with
Japanese laws and regulations. However, the MHLW has confirmed that this confirmation page
does not make the website legal. See screenshot below.
Fig 5: BestKenko website entry acceptance screen (source: bestkenko.com/templates/bk3/images/welcome.jpg)
!
24
Below are full-page screenshots of the four BestKenko flagship Internet pharmacy
websites.
Fig 6: Screenshots of flagship BestKenko pharmacy websites
bestkenko.com
kusuriexpress.com
petkusuri.com
genkipet.co
From the perspective of the average Japanese Internet user, the BestKenko websites seem
eminently reassuring. For example, the home page of bestkenko.com shows three Japanese
physicians smile out at the Internet user, next to an image offering “100% assurance” of drug
authenticity, effectiveness and delivery. The website, written entirely in flawless Japanese, offers
25
assurances to “first time customers” that the website is completely legal, and offers –– mostly, at
least –– pristine pictures of familiar Japanese medicines. The customer is told that the medicines
have been approved for safety by the US Food and Drug Administration.51 The prices are in yen,
and a page offers multiple testimonials, apparently from Japanese residents, as to their
satisfaction regarding the medicines provided by bestkenko.com. To any Japanese Internet user,
it would seem that bestkenko.com offers a fully legal, entirely safe, website selling prescription
medicines, marrying the best of the Internet with online healthcare fully regulated for safety.
The truth, however, is starkly different. In fact, bestkenko.com has no affiliation
whatsoever with any Japanese physician or pharmacy, despite the marketing. The drugs are not,
for the most part, approved for sale in Japan, and are not sold by any licensed pharmacy in Japan
or any other location. Although the website claims that the medicines have been approved for
safety by government agencies such as the US Food and Drug Administration, most of the drugs
sold on the BestKenko websites are not approved by the US Food and Drug Administration. 51
http://www.bestkenko.com/pages/%E9%85%8D%E9%80%81%E6%96%99%E9%87%91%E3%81%AB
%E3%81%A4%E3%81%84%E3%81%A6.html
http://www.bestkenko.com/kb/search/%E3%83%88%E3%83%A9%E3%83%83%E3%82%AD
%E3%83%B3%E3%82%B0
26
7.0 Payment and Merchant Accounts BestKenko allows customers to pay for their orders using credit card or bank transfer
payments. Accepted credit cards are Visa, JCB, and American Express (AMEX). As previously
mentioned in Section 3, describing the network operators, BestKenko has used the merchant
name PetKusuri as its primary merchant account name for Visa and AMEX cards, and it is used
for both pet and human medicine credit card payments. The merchant account names that are
used for JCB credit card payments include PetKusuri and a second merchant name, GenkiPet.
Specifically, the JCB credit card merchant accounts are identified as
AW*petkusuri.com656777768352 and AW*genkipet.co656777768353 on petkusuri.com and
genkipet.co, respectively.
The Singapore telephone number +65.67777683, represented in the PetKusuri and
GenkiPet billing descriptors above, is also used in the domain name registration for
petkusuri.info, where the registrant is Vista Pharma (aka Alps Pharmacy). Like petkusuri.com,
the genkipet.co website identifies Robin SCRIMGEOUR’s Ichikado, Ltd. as the management
company.54
In July 2015, LegitScript worked with Visa to terminate the BestKenko merchant account
identified as PetKusuri. The merchant identifier was WWW.PETKUSURI.COM and was
identified as being serviced by a Luxembourg bank, Catella Bank S.A. An unverified online
response to the termination of the merchant account concluded that the network had been
closed.55 This seems premature: subsequent LegitScript review of the flagship Internet pharmacy
52
http://www.petkusuri.com/pages/%E3%81%8A%E6%94%AF
%E6%89%95%E3%81%84%E6%96%B9%E6%B3%95%E3%81%AB%E3%81%A4%E3%81%84%E3%81%A6.html
53
http://www.genkipet.co/terms-and-conditions
54
http://www.genkipet.co/terms-and-conditions
55
http://医薬品輸入代行.com/
%E3%83%99%E3%82%B9%E3%83%88%E3%82%B1%E3%83%B3%E3%82%B3%E3%83%BC%E3%81%8C
%E9%96%89%E9%8E%96.html
27
payments. As this report was being finalized, LegitScript identified four new merchant identifiers
used by BestKenko: RNOP 0000-000-000, MTUM 0000-000-000, MNO 0000-000-000 and
GDL 0000-000-000 (“0” refers to numbers that are assigned by BestKenko; thus, “0” may be
replaced by other digits on a credit card statement). We are still researching the new acquiring
bank providing payment processing services to the network.
BestKenko network payments made to affiliates are transferred using Paypal
(paypal.com). The BestKenko affiliate PayPal merchant account is unknown to LegitScript but
will be researched and identified in the near future. 28
8.0 Conclusion BestKenko is a network of illegal online pharmacies targeting Japan operated by a small
group of private investors that includes Singapore-based Mark RADFORD and Robin
SCRIMGEOUR, Japan-based partner Joel DEVIDAL, and India-based drug suppliers SAVA
Global and Vaijanti Pharma. RADFORD has a professional background in marketing and
telecommunications sales prior to his involvement with such startup and small companies as
OneNrg and DialUsNow, the founding business of the BestKusuri/BestKenko network.
RADFORD partnered with DEVIDAL in DialUsNow. DEVIDAL’s expertise is Internet coding,
Internet payment gateways, small-business startup, and affiliate marketing. Robin
SCRIMGEOUR, a Director of Rajah Blue Holdings and the registrant of Ichikado, Ltd., the
BestKenko trademarks and payments owner, worked in investment banking and equity trading
before moving to private capital investing, most recently with Rajah Blue Holdings Pte. Ltd., the
investment company that manages the BestKenko distribution partner, Scanpro Pacific Pte. Ltd.
Both SCRIMGEOUR and RADFORD are directors of Rajah Blue, which RADFORD describes
as “… a diverse range of investments across different geographies on behalf of the stakeholders,
invests in seed-stage startups and operates an active business incubator from its shared service
facility in Singapore.”56 With this type of business description, the Singapore partners are able to
attract a variety of affiliates who work in Japanese and Pan-Asian markets.
Review of the current BestKenko domain name registrants in the BestKenko DNW, along
with LegitScript current and historical correspondence with individuals who are involved in
registration of BestKenko domain names and the operation of the associated websites, indicates
that the BestKenko network is able to attract two types of affiliates. The first type includes
Internet marketing and service providers who may believe they are working with a legitimate
56
29
https://sg.linkedin.com/pub/mark-radford/9/813/717
business. This first group of affiliates includes Pagerise Pty Ltd. (pagerise.com — offline)57, 58
which corresponded with LegitScript regarding the original BestKusuri websites and a current
Japanese affiliate, Apple Seeds (a-seeds.com), an Internet marketing service company that
operates the customer recruitment website daisuki-pet.com. The second group of affiliates
identified in the BestKenko DNW operate websites that affiliate with multiple illegal Internet
pharmacy networks that target Japan, including the Roy Union and RxCash.biz networks
mentioned at the beginning of this report and other Japanese-language networks such as Net
General Hospital. This second group of affiliates most likely know that by working with
BestKenko, they are working with a pharmacy network that illegally sells drugs to Japanese
customers. These affiliates, whose names appear in some of the BestKenko non-anonymous
domain name registrations, include Yugo Hosado (Facebook), Jun Saito, and Osamu Makino.
Neither group of affiliates appear to control the operations of the BestKenko network.
The owners of the BestKenko network, including DEVIDAL, RADFORD,
SCRIMGEOUR, and the drug supply partners SAVA Global and Vaijanti Pharma, have operated
the BestKusuri/BestKenko network since at least 2010, and have done so despite legal actions
such as the Bayer intellectual property lawsuit and the website shutdowns requested by
LegitScript on behalf of the Japanese MHLW. The BestKenko network continues to be a major
health risk for Japanese consumers and remains a target for continued law enforcement and
private sector action intended to stop or curtail its illegal and prolific activities.
30
57
https://www.wantedly.com/companies/pagerise
58
https://blog.legitscript.com/2012/10/bestkusuri-com-japanese-rogue-pharmacy-linked-to-singapore-internet-firms/

Sample Report

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