This is the story of how the World Health Organisation (WHO) came to partner with Interpol and the pharmaceutical industry to fight a war against fake drugs. This partnership took the form of a taskforce, the International Medical Products Anti-Counterfeit Taskforce (IMPACT), which contributed greatly to how counterfeit drugs became understood as a threat to health and fought as a matter of organised crime. But today, 20 years later, hardly any trace can be found of its existence or its activities. It is as if it never happened and the WHO had never been involved. How is this possible? By looking at the taskforce as a kind of middleman, we get a better sense of how this unusual institutional arrangement between WHO, Interpol and the pharmaceutical industry could be publicly celebrated as an act of resolve and forcefulness in one moment, and then be shunned and denied the next.
Based at the University of Zurich as an anthropology lecturer in the early 2000s, I conducted ethnographic research at the WHO and carried out extensive interviews with WHO, pharmaceutical industry, and Interpol stakeholders involved in IMPACT. This allowed me to document how IMPACT operated before its activities were erased from institutional memory. Combined with a deep dive into the WHO online and the Interpol media archives, this material has enabled me to reconstruct the curious, short-lived, yet significant episode in the history of a taskforce.
It all started in 1985 at the seminal WHO conference entitled The Rational Use of Drugs, held in Nairobi. There, the issue of fake medication was mentioned for the first time as a possible concern for the WHO, though more as an afterthought than a top agenda item (WHO 1987). A few years later, the matter was raised again during the 1988 World Health Assembly. Delegates from Hungary worried ‘that in some countries a number of drugs, mainly those arriving by unofficial channels, are counterfeit and substandard,’ and asked ‘How could such drugs ever be used rationally?’ (WHO 1988a, 84-85). Other delegates were easily swayed by the threat to health which such fake drugs presented. They agreed that fake drugs needed to be treated with the same resolve as illicit drugs, namely as a criminal matter if not a security concern. This is how the matter of fake drugs was catapulted from an afterthought into an explicit concern itemized in the WHA41.16 resolution (WHO 1988b). Having taken this palpable shape, it consequently compelled the WHO Secretariat into action.
Yet the Secretariat was aware that neither its staff nor national health inspectors could deal with this alone. The WHO Secretariat’s coordinator of IMPACT, put it in 2011: ‘If you want to investigate where the counterfeits come from and how they come, you need to be doing enforcement work. It is not pharmaceutical inspectors who can do that, [they] don’t have the power.’ This is the moment when the WHO started talking to Interpol, the International Police Organisation (WHO 1992, 4). What started out as an awkward encounter – as there was no precedence for such a collaboration – soon became an enthusiastic union. The WHO conceded that it needed proper executive powers to carry through search, seizures and arrests, and the ability to draw on crime intelligence to confront the global criminal networks that were assumed to be behind fake drugs. They also roped in the pharmaceutical industry, the holder of secrets, urging them to be more munificent in sharing data on their products being faked, even if this might compromise their brand names at times (WHO 1992).
It must be mentioned here that all this happened even though the extent of the threat was utterly unknown and purely anecdotal. A WHO expert recalled that ‘somebody invented the 10% [statistic] just to get interest. He gave it away to journalists. It was one of our colleagues.’ The expert was convinced that it was this invented statistic, that 10% of all medications being consumed are fake, that triggered the next step: the ‘Joint WHO/IFPMA Workshop on Counterfeit Drugs’ where all parties would be forged into a team ready to tackle the circulation of fake drugs. Dr Hu Ching-Li, one of the Assistant Director-Generals of the WHO, closed that conference with a motivational shout-out: ‘If we all work together – industry, WHO, drug regulators, police and customs – we must, and will, succeed.’ Cheered on by national regulatory agencies (WHO1996) this collaboration was firmed up and formalised in 2006 in the so-called Rome Declaration, which served as the founding document for IMPACT.[1]
So convivial was the relationship of the taskforce partners that the WHO made space for it in its Geneva headquarters, even furnishing an office to one of Interpol’s people.[2] Together, members of the WHO Secretariat and the delegate from Interpol planned and executed a whole range of policing operations, including Operation Storm in Southeast Asia; Operation Pangea, focused mainly on Northern countries and internet trade; and, finally, Operation Mamba I, II, and III, a set of operations carried out in East African countries. Each of these operations were proudly brought to the public’s attention through headlines such as “Operation Mamba (Impact) – targeting counterfeit medicines in Tanzania”;[3] “Police across Southeast Asia target counterfeit medicines in multi-agency operation,”[4] or “Illegal online medicine targeted in first internet day of action.”[5] Each of these press releases, showcasing their successes, featured the numbers of arrests and/or quantities of suspicious medications seized. For example, one press release trumpeted: “In Tanzania 191 locations, including pharmacies, warehouses and illicit markets, were inspected resulting in the seizure of 100 types of products. […] Police closed four pharmacies, and 18 drug shops found to be in breach of the law. A total of 44 police cases were opened.”[6]
With the acceleration of IMPACT’s activities, the WHO Secretariat found itself able to respond efficiently to member states’ rapidly growing concerns about fake medications. It also capitalised on the appeal of the taskforce as a form of governance built not on stable institutions but on networks and the ability to connect people and things (Boltanski and Chiapello 2005). Interpol, meanwhile, found that assuming the mantle of protecting public health significantly amplified its moral authority and relevance. The pharmaceutical industry, for its part, could position itself as genuinely invested in the safe consumption of its products. “It is a win-win situation!” exclaimed an Interpol officer based at the WHO (interview with Interpol officer, 2010).
However, as already mentioned, if one were to look now, in 2026, at this episode of collaboration, one would find nothing. The internet archival sources, which 15 years ago abounded with mentions of raids and special operations carried out under the IMPACT’s name, are simply missing. What happened?
By applying the analytic lens of middlemen onto this short-lived three-way marriage of the WHO, the police and the pharmaceutical industry, we can see that IMPACT’s strength was also its weakness. As I will show, one moment it was seen as uniquely bringing together all that was needed to fight fakes – a fight in which the health agenda was paramount, but law-enforcement muscle and industry expertise and secrets were also needed. In the next moment, IMPACT was seen as a henchman to Big Pharma and its commercial interests.
To understand this, let me lay out before you some of the classic – in the sense of old-style but also enduring – ideas about how to think with the middlemen (as we do in the introduction to this special series). Sidney Mintz (1956), in The Role of the Middleman in the Caribbean Peasant Economy, argues against the widespread disparaging image of middlemen as parasitic. This image assumes that middlemen put themselves opportunistically between producers and customers in order to take a cut of the profits earned by hard-working farmers, with the effect of making goods more expensive for customers. To counter this notion of the middleman, Mintz shows how middlemen provide an essential service. Looking at daily produce market interactions, he shows that middlemen possess specific acumen that helps in bringing products to market and making sure they get sold. This acumen is carefully tailored to the product, be it easily perishable goods, like avocados, which need to be packaged and transported in a certain way and sold within a short period of time, or longer-lasting goods like sugar cane, which can be brought to market when other traders have to leave already to make it home in time. Mintz (1956: 23) makes clear that middlemen are “not economically redundant but actually essential to the distributive process.” Without their special acumen and motivation to read the market and manoeuvre accordingly, the local economy would cease functioning. Farmers would not be able to tend their fields if they had to take their goods to the market themselves, which means that consumers would not be provided with the diversity of goods they require and desire. Like a market middleman, IMPACT connected different actors in a way that served each one’s needs. It brought to the WHO’s health agenda the skill and acumen – executive force, and criminal and industry intelligence – it lacked within its ranks of public health bureaucrats and specialists. And it brought to both Interpol and Big Pharma the veneer of moral action.
Georg Simmel (1908), in a closely related way to Mintz, shows how “the stranger,” epitomised in the role of the traveling trader, equally fills a gap by its very nature of coming from outside. The stranger’s ‘position in this group is determined, essentially, by the fact that he has not belonged to it from the beginning, that he imports qualities into it, which do not and cannot stem from the group itself” (Simmel 1908: 1). Therefore, rather than being seen as a threat, a stranger brings foreign skills and qualities that are seen as an asset. Furthermore, the stranger comes free of any baggage: he has no alliances and biases towards any faction; he is the friend of anyone and no one. This makes him particularly trustworthy, and people tend to seek his advice and judgment (Simmel 1908: 2). This is how IMPACT was treated by the WHO: it brought something new and unique to the table, yet by being its own taskforce, it remained distinct from the WHO. Interpol was especially seen as a ‘stranger’ to the field of public health. They were greeted enthusiastically, with nobody expecting them to have any major stakes themselves in fighting fake drugs beyond what they were meant to do anyway, namely fighting crime. The pharmaceutical industry had been conscripted into the taskforce under the same bearing, to provide intelligence and to fight crime.
However, if we follow the figure of the middleman to its conceptual limits, we find that both the middleman and the stranger share what might be called a thin identity. Their defining trait is their ability to occupy interstitial spaces without fully belonging. This lack of rootedness makes them useful, yet they are also thought of as superfluous and subjected to suspicion. As Mintz (1956) notes, middlemen are often viewed negatively as driven by profit into arrangements where they have no grounds to belong. Similarly, Simmel (1908: 2) observes that the stranger’s freedom to maintain a ‘bird’s-eye view of relationships’ ‘contains many dangerous possibilities,’ for in times of upheaval, outsiders are easily cast as instigators. Not belonging with ‘us’ can quickly be read as belonging with the wrong ‘others.’ Like the optical illusion where a young woman becomes an old woman with a blink of an eye, the very position that enables the middleman or stranger to mediate so effectively becomes the ground for people turning against them, pointing fingers and driving them out.
Being turned from dependable friend into suspicious crook is what happened to IMPACT. In 2008, during the 61st World Health Assembly, IMPACT experienced a dramatic fall from grace. Once seen as a trusted ally, its virtue was suddenly cast into doubt. The WHO and its strategic partnership with law enforcement and the pharmaceutical industry to fight the fight against fake drugs began to appear as corrupt. Critics argued that Big Pharma was not there to advance an agenda of securing access to health but had its own self-interested agenda in the fight against counterfeit drugs: discrediting generics and protecting their competitive advantage by enforcing intellectual property rights. In short, IMPACT was accused of trying to block efforts to improve access to affordable medicines for the poor.
Looking back, observers describe IMPACT’s downfall as a pivotal moment when previously separate issues collided explosively. In one room, the Nigerian delegation and its European and African allies were still advocating for IMPACT’s mission, pushing for an expanded mandate and increased funding (WHO 2008a). Next door, delegates decried the harmful effects of a narrowly defined intellectual property agenda on access to health (WHO 2008b). These concerns were carried across rooms by representatives from Thailand, India and Argentina, with a Brazilian delegate stating plainly: “WHO has a crucial role in promoting health issues, and that should not be mixed with law enforcement measures, which might be interpreted as a means to drive out producers of legitimate generics” (WHO 2008a).
Awareness of the dangers of an Intellectual Property (IP) driven agenda had grown exponentially in the post-Trade-Related Aspects of Intellectual Property (TRIPS) era, amid fierce debates over the interpretation of its flexibilities, including the parallel imports of antiretrovirals (ARV) during public health crises (Cloatre 2013). From this perspective, IMPACT suddenly appeared as a Trojan Horse, allowing Big Pharma to infiltrate WHO’s inner circle and influence policy implementation to their advantage.
With this sudden and momentous twist in the collaboration between the WHO Secretariat, Interpol and the pharmaceutical industry, none of the parties were given a chance to defend themselves. No matter how much those invested in creating IMPACT tried to distinguish between interests, urgencies and motivations, their efforts failed. From the start, IMPACT had been an interstitial, subsidiary outsider – like most middlemen, it was never seen as having its own rationale or identity. The narrative allowed only two interpretations: either IMPACT served WHO’s lofty agenda or it served Big Pharma’s.
Led by the Brazilian and Indian health missions in Geneva, vocal critics successfully argued that WHO’s very raison d’être was at stake. They insisted that IMPACT – and with it, WHO’s collaboration with police and drugmakers – must be abandoned immediately. Rejecting any compromise, they even managed to fracture the coalition of African countries who feared losing out if police and pharma withdrew their attention from combating fake medicines.[7]
In the end, history was rewritten. In 2012, a new resolution was passed that made no mention of the previous activities or resolutions on which IMPACT had been founded. As if starting from day one, this resolution established an entirely new process: the Member State Mechanism (MSM). Its activities – ‘information exchange,’ ‘technical support,’ and ‘norm setting’ (WHO 2012) – were the soft tools a health institution could offer to combat fake medicines; no longer was there any mention of the law enforcement power of the police or the insider knowledge of the pharmaceutical industry.
With this shift, the drug-security rationale – which conceived of fake medication as the product of organised crime and criminal intent – was replaced by a drug-safety rationale. This approach assumed that fake drugs could be outcompeted by affordable generics and that their existence was driven by ignorance rather than malice. Consequently, soft regulatory measures were seen as sufficient to transform bad practices into best practices (Hornberger 2018). It was as if the whole concern that produced IMPACT had been nothing more than crying wolf. And perhaps it was, given that the scale of the fake medicine problem had always rested on shaky evidence and invented numbers, especially the infamous ‘magic 10%.’[8]
Ultimately, what we see here is that IMPACT’s position as an interstitial middleman was precisely what made it so attractive. It filled a gap that no one else could, tackling a problem – real or imagined – with a unique acumen at a time when fake medicines were framed as a major criminal threat. Yet, sitting at the intersection of competing agendas and working styles also made IMPACT vulnerable to accusations of partisan bias. In the blink of an eye, its mission of protecting access to health could be reinterpreted as serving other interests. Its lack of a clear identity meant it could not distinguish itself from the agendas surrounding it. And being a middleman also meant having no independent significance beyond its ‘betwixt and between’ position. Once support faded and the WHO was asked, in no uncertain terms, to disavow its former attraction, IMPACT’s historical record – by then an embarrassment for WHO – could simply be erased (WHO 2012).
What remains, then, is a remarkable absence. The ease with which WHO’s collaboration with the taskforce was erased from the record belies the impact of IMPACT, the effects of the middleman that unfurled, despite its nondescript identity. Before its fall from grace, IMPACT, as WHO’s fixer, had given form and substance to the figure of fake drugs through forceful interventions, publicity campaigns, guidelines, partnerships and a stream of memos and charters (IMPACT 2011). It framed fake medicines as a criminal matter and, more importantly, as an urgent threat to health.
This figure, once brought to life, does not simply fade away – quite the opposite. Unlike the middleman, whose identity is fragile and easily erased, the figure of fake drugs thrives on its overdetermined identity. It persists without evidence, traveling from context to context, carrying its sense of urgency into new arenas, and compelling further action (Hornberger and Hodges 2023).
And indeed, that is exactly what happened: the figure of fake drugs has been traveling widely and effectively ever since. Once cut loose from its womb at the WHO – where it had been imbued with the authentic force to evoke a health threat – it was free to roam and be adopted. One of its keen adopters was the police. Interpol, having been part of IMPACT, had learned how attractive it was to fight fakes in the name of protecting public health. For policing, which is often in crisis, such moral high ground is rare. Unsurprisingly, they had little desire to relinquish this newfound mission. Instead, they established their own Illicit Goods and Public Health program.[9]
Freed from WHO’s watchful eye, Interpol could partner with whomever it chose in its self-defined fight against fake drugs. And they chose not only the pharmaceutical industry but the entire brand-based industry, who were also eager to enlist police support. The industry’s goal was not merely to have intellectual property rights enshrined in international and national legislation, but to ensure states actively enforced these rights through local police and prosecutors (Hornberger 2024). Here, the specter of fake drugs – evoking visceral fears of patients being killed by the very medicines meant to cure them – conveniently provided urgency and legitimacy for cracking down on all forms of counterfeiting (Hornberger and Hodges 2024). This leaves us with an important insight about the role of middlemen in global health: while middlemen often remain invisible, or their traces are easily effaced, what they leave behind and what they set into motion can be momentous. Looking back, we are left wondering not only where these shifts originated but how their logic continues to shape alliances, agendas and enforcement practices long after the middleman has disappeared.
[1] See link (no longer accessible) at “Declaration of Rome” www.interpol.int/public/ICPO/speeches/SGWipo20070.
[2] See link (no longer accessible) at http://www.interpol.int/Public/ICPO/GeneralAssembly/AGN7.
[3] See link (no longer accessible) at “Operation Mamba (Impact) – targeting counterfeit medicines in Tanzania,” Interpol, www.interpol.int/public/news/2008/mamba20081029.asp
[4] See link at (no longer accessible) “Police across Southeast Asia target counterfeit medicines in multi-agency operation,” Interpol, www.interpol.int/public/icpo/pressreleases/pr2008/pr200865.asp
[5] See link at (no longer accessible) “Illegal online medicine targeted in first internet day of action,” Interpol, http://portal.interpol.int:1967/public/icpo/pressreleases/pr2008/pr200863.asp
[6] [6] See link (no longer accessible) at “Operation Mamba (Impact) – targeting counterfeit medicines in Tanzania,” Interpol, www.interpol.int/public/news/2008/mamba20081029.asp
[7] Interview with Interpol official, June 2012.
[8] Interview with WHO expert, January 2011.
[9] See link at “Illicit Good and Global Health,” Interpol, www.interpol.int/content/download/5263/file/Illicit%2520goods%2520and%2520global%2520health.pdf.
References
Boltanski, Luc, and Ève Chiapello. 2005. The New Spirit of Capitalism. Translated by Gregory Elliott. London: Verso.
Cloatre, Emilie. 2013. Pills for the Poorest. An exploration of TRIPS and access to medicines in sub-Saharan Africa. London: Palgrave Macmillian.
Hornberger, Julia and Sarah Hodges. 2024. ‘Policing Fakes.’ The Cambridge Journal of Anthropology 42 (2): 1-14. https://doi.org/10.3167/cja.2024.420202.
Hornberger. Julia. 2024. ‘The gospel of fakes: policing, intellectual property conferences and the problem of persuasion.’ The Cambridge Journal of Anthropology 42 (2): 15-30. https://doi:10.3167/cja.2024.420203.
Hornberger, Julia and Sarah Hodges. 2023. ‘Fake Talk as Concept and Method.’ Medicine Anthropology Theory. 10 (3):1-22. https://www.medanthrotheory.org/mat/article/view/7291.
Hornberger, Julia. 2018. ‘From Drug Safety to Drug Security: A Contemporary Shift in the Policing of Health.’ Medical Anthropology Quarterly 32 (3): 365–83. https://doi.org/10.1111/maq.12432.
Impact. 2011. ‘IMPACT. Facts, Activities, Documents Developed by the Assembly and the Working Groups 2006-2010’. Rome: Italian Medicine Agency.
Mintz, Sidney. 1956. ‘The Role of the Middleman in the Internal Distribution System of Caribbean Peasant Economy’. Human Organization 15(2): 18-23. https://doi.org/10.17730/humo.15.2.x5k4022515r6068u.
World Health Organisation. 1987. The Rational Use of Drugs: Report of the Conference of Experts, Nairobi, 25–29 November 1985. Geneva: WHO.
World Health Organisation. 1988a. Summary Records of the Committees. WHA41/1988/REC/3. Geneva: WHO.
World Health Organisation. 1988b. World Health Assembly Resolution WHA41.16, “Rational Use of Drugs. Geneva: WHO.
World Health Organisation Division of Drug Management and Policies. 1992. Counterfeit Drugs. Report of a WHO/IFPMA Workshop, 1-3 April 1992. WHO/DMP/CFD/92. Geneva: WHO.
World Health Organisation.1996. Proceedings of the Eighth International Conference on Drug Regulatory Authorities (ICDRA), Bahrain, 10-12 November. WHO/DMP/ICDRA/1997.1. Geneva: WHO. https://iris.who.int/handle/10665/69794.
World Health Organisation. 2008a. Summary Records of Committees. A61/2008/REC3, WHA 61, Geneva 19-24 May. Geneva: WHO.
World Health Organisation. 2008b. Report of the Intergovernmental Working Group on Public Health and Intellectual Property (PHIIP), A61/9. Geneva: WHO.
World Health Organisation. 2012. Sixty-Fifth World Health Assembly Geneva, 21–26 May 2012, Resolutions and Decisions, Annexes, WHA65/20212/REC/1. Geneva: WHO.
Simmel, George. 1908. ‘Der Fremde’. In Soziologie: Untersuchungen über die Formen der Vergesellschaftung. Leipzig: Duncker & Humblot.
