The Illicit Medicines Market in Colombia: A Silent yet Traceable Threat

The World Health Organization estimates that around 30% of the medicines sold in the region are illegal products (Fedefarma, 2023). As a result, the illegal trade in medicines has become one of the fastest-growing and least visible criminal phenomena in Latin America. Far from being a marginal problem, this activity erodes confidence in health systems, endangers patients' health, funds criminal groups, and causes significant economic losses for the legitimate pharmaceutical industry and for the public purse.

Colombia is one of the most affected markets in the region. Illegality in the sector is widespread: counterfeit, adulterated and smuggled medicines, as well as products diverted from institutional use. According to the Global Organized Crime Index (GI-TOC, 2025), counterfeit medicines are among the three most recurrent products in the country, and they are distributed openly through informal markets, pharmacies in small towns and rural areas, and digital platforms. 

Over the past five years, law enforcement authorities have seized approximately USD 25 million in illegal medicines, amounting to more than 11 million units removed from circulation (CIMA). For its part, INVIMA issued 167 health alerts in 2025, while 154 have already been issued so far in 2026 (up to September), pointing to a rising trend. This is consistent with Strategos BIP's negative outlook, which stems in part from pressures on the health system that have caused shortages and limited access to certain medicines, from the capture of this sector by criminal organisations, and from the ease of selling in digital ecosystems (Strategos BIP, 2026).  

A transnational phenomenon: the illicit supply chain

In addition to being highly vulnerable to illegality in the sector, Colombia is also a relevant node within networks operating on a transnational scale (GI-TOC, 2025). Smuggling illustrates how much of this market interacts beyond its borders. 

The DIAN (2025) notes in its latest annual smuggling report that Germany is the third-largest country of origin for technical smuggling through under-invoicing in Colombia, with insulin-containing medicines being the main product at risk from that country. Through our CIMA platform, we have verified that this risk signal, in 2024, extends more broadly to all pharmaceutical products (tariff heading 30): four of the five main countries of origin of these medicines show significant discrepancies between what is reported as exported and what is actually imported into Colombia, discrepancies that merit in-depth analysis.

Tied into international supply, health alerts from different countries suggest a degree of transnational convergence among the criminal networks behind this phenomenon. Nine health alerts issued between 2018 and 2025 in three countries – Colombia, Ecuador and Mexico – show how the same medicine, a growth hormone, was distributed across several countries over these years, in some cases even with the same batch number. An industry source confirmed cases of diversion of this hormone from Colombia to Mexico.

In a recent investigation, we also verified in the field how the cross-border insulin market from Colombia (Cúcuta) to Venezuela is supplied with adulterated medicines, products diverted from institutional use, openly smuggled goods and products with no cold chain, endangering patients' health.

The rise of digital sales: the key is to identify, profile and prioritise

At the end of the supply chain lies another factor that has driven this illicit market: sales on digital platforms. Today, a significant share of this illegal supply reaches consumers through marketplaces and social media groups. In our investigations, we have found that two types of actors, with different logics but equally risky effects, converge in these spaces. 

On the one hand, there are consumers who resell leftovers from their own treatments. On the other, there are actors with logistical and financial capacity who profit from stolen, diverted, smuggled or counterfeit medicines. Although both pose risks to the quality of the medicine, this second group represents a considerably higher risk, both because of the volumes it can move and because of its ability to disguise the illicit origin of the product through packaging, seals and presentations that imitate the originals with growing sophistication. Identifying and differentiating these actors, and understanding how their accounts are interconnected, is critical to better prioritising corporate investigations and those of government agencies.

Towards a more coordinated response

In light of this situation, pharmaceutical companies need ever greater information-analysis capabilities to detect cases of illegality that affect their patients, brands, supply chains and markets. The best brand protection and corporate security departments have combined reaction with prevention; controlled purchasing with supply chain analysis; the takedown of digital sales listings with the profiling and understanding of the links between those operating behind digital fronts; and reporting with operational coordination with the authorities. 

Is your organisation prepared to face

the sophisticated risks of illegal trade?

At Strategos BIP, we are your allies against illegal trade. We support more than 14 industries in preventing and combating smuggling, counterfeiting and unfair competition in their sectors: analysing illegal supply chains, profiling critical networks and actors, and coordinating efforts with the authorities to protect consumers, brands and markets.

📩 Info@strategosbip.com to arrange a risk assessment of your company and to explore how we can strengthen your protection strategy.

References

Agencia Nacional de Regulación, Control y Vigilancia Sanitaria. (2018, 2 de marzo). Alerta sobre falsificación de lote de medicamento SAIZEN (SOMATROPINA). https://www.controlsanitario.gob.ec/alerta-sobre-falsificacion-de-lote-de-medicamento-saizen-somatropina/ 

Buitrago Arias, J. C., y Ruiz Galán, J. (2026, 23 de febrero). 10 Riesgos de Comercio Ilegal en Latinoamérica (2026). Strategos BIP. https://www.strategosbip.com/post/riesgos-comercio-ilegal-latinoamerica-2026

Comisión Federal para la Protección contra Riesgos Sanitarios. (2024, 26 de junio). Cofepris alerta sobre falsificación de hormona para el crecimiento (Comunicado de Prensa N.º 91/2024). Gobierno de México. https://www.gob.mx/cofepris/articulos/cofepris-alerta-sobre-falsificacion-de-hormona-para-el-crecimiento?idiom=es 

Dashboard de Decomisos - Medicamentos . CIMA - StrategosBIP. https://cima.strategosbip.com/Panel/panel-stratego

Instituto Nacional de Vigilancia de Medicamentos y Alimentos. (2025). Alerta Sanitaria No. 369-2025: Producto Falsificado SAIZEN 20 mg/2.5 mL (8mg/mL) Lotes BA068280 y EC179361. https://www.invima.gov.co/biblioteca/alerta-sanitaria-saizen-falsificado-lotes-ba068280-ec179361 

Instituto Nacional de Vigilancia de Medicamentos y Alimentos. (s. f.). Alertas sanitarias medicamentos y productos biológicos. Invima. Recuperado el 22 de septiembre de 2026, de https://app.invima.gov.co/alertas/medicamentos-productos-biologicos 

Global Initiative Against Transnational Organized Crime. (2023). Colombia: Global Organized Crime Index. https://ocindex.net/country/colombia