Page 31 - gs260402

Insights and Expertise

com/kp26ez9u). The FDA has also noted that 7-OH is
Red flags in digital health commerce far more potent than morphine (see https://tinyurl.
com/yc26k82r).
Here are several warning signs payment providers and
platforms should watch for: Because there is currently no federal ban in the United
• "For research purposes only" disclaimers on States, 7-OH products remain widely available online,
consumer-facing products often sold as inexpensive tablets and gummies.
• Social media-driven spikes in demand for niche (End indent)
compounds What ecommerce platforms must do now
• Bundled supplement offerings with inconsistent The reality for ecommerce platforms and professionals
labeling is that healthcare-related risks are now embedded across
• Merchants offering "worldwide shipping" without wellness, beauty, supplements, and lifestyle commerce.
jurisdiction controls The use cases aren't always obvious. In fact, bad actors will
• Frequent domain changes or mirrored storefronts go great lengths to hide illicit online sales, disappearing
and reappearing across platforms, and using sophisticated
• High-risk product categories (weight loss, sexual techniques such as front sites and transaction laundering.
enhancement, biohacking)
Digital commerce platforms and payment providers sit on
merchant on a large marketplace or bundled into a the front lines. They see merchants before regulators do,
site that otherwise falls within acceptable risk toler- which means they have both the power and responsibility
to cut off access to dangerous products and protect
ance. consumers.
This makes it less an isolated product problem and
more a pattern-recognition challenge. It requires e- Practical steps to take include:
commerce platforms and service providers to detect
more sophisticated risk signals, even beyond product • Gain deeper visibility into your merchants. Risk
evaluation can't be static or superficial. After a
names.
comprehensive risk assessment at onboarding,
• Cross-border complexity: A major challenge in on- merchants must be regularly reassessed. Businesses
line health commerce is variability of regulation: that were low-risk years ago may now ship products
that materially change their (and your) risk exposure.
what's legal in one jurisdiction can be a controlled
substance or prescription-only drug in another. The • Monitor warning signals. Effective risk management
risk calculus changes dramatically based on a prod- requires continuous monitoring. Things like bundled
uct's destination. products, red-flag phrases, and social media-driven
Merchants offering "worldwide shipping" on large demand spikes can reveal potential violations long
before regulators intervene.
supplement inventories are potentially selling prod-
ucts restricted somewhere in their shipping range. • Evaluate cross-border shipping practices. Platforms
Ingredients common in U.S. supplements, such as must understand not just what is being sold, but where
DHEA, yohimbine and melatonin, require prescrip- it is being shipped, and whether those products are
tions in multiple countries. lawful in destination jurisdictions.
Ecommerce platforms and payment providers must A front-line responsibility
account for these differing regulations when assess-
ing risk for cross-border merchants. The US is a ma- The online wellness commerce landscape is evolving
jor global supplement producer, but ingredients com- faster than any single regulatory body can address.
monly sold in U.S. supplements may be prohibited in Consumer demand is creating enormous market pressure,
other jurisdictions. while fragmented global regulation creates gaps that can
• Emerging compounds and psychoactive substances: be exploited. If that weren't enough, the speed of digital
transactions allows bad actors to move products faster
Emerging and psychoactive compounds are areas
where future risk is likely to intensify—and it's than traditional enforcement can respond.
moving fast. Compounds such as 7-OH, kratom, and
psychoactive mushrooms have caught the attention As the risks continue to migrate into mainstream
ecommerce, platforms and payment providers increasingly
of regulators for the potential risks to consumer
health, but they are still actively sold online. serve as the first line of defense. They often see emerging
threats before regulators do. It's no longer a niche concern,
7-hydroxymitragynine (7-OH) has become a but a core commerce risk that demands proactive oversight
particularly hot topic recently. On July 29, 2025, the and informed action.
FDA recommended a scheduling action to control
7-OH under the Controlled Substances Act, warning Niamh Lewis is the vice president of compliance operations at G2 Risk
of the potential for abuse and harm (see https://tinyurl. Solutions. Contact her at niamh.lewis@g2risksolutions.com.
31