High-risk Trends Series: Problematic Products

Dealing with high-risk portfolios adds complexity to a PF’s compliance efforts, presenting potential headaches as they look to keep up with a rapidly changing landscape under heightened regulatory and card brand scrutiny. This week, we begin an occasional series on the trends that are facing payment facilitators operating in the high-risk space. 

David Khalaf, LegitScript

A major challenge for payment facilitators entering the lucrative supplement and pharmaceuticals spaces is navigating the dizzying number of products. There are hundreds of thousands of supplements, pharmaceuticals, and other products regulated by the Food and Drug Administration, with many more added every week. How can payment facilitators mitigate risk while onboarding and monitoring these merchants?

One key approach is to keep abreast of trends about the types of problematic products that are gaining in popularity or that exist in regulatory gray areas. Knowing what types of products are most likely to cause problems or draw regulatory scrutiny can help you watch for them and act before they lead to fines related to Visa’s Global Brand Protection Program (GBPP) and Mastercard’s Business Risk Assessment and Mitigation (BRAM) compliance programs.

Below are the top five trending high-risk products you should know about.

Cannabidiol (CBD)

Few products in recent years have promised as much opportunity for payment facilitators as CBD. With the passage of the 2018 Farm Bill, hemp and CBD have been removed from the DEA’s Controlled Substances schedules entirely, opening what is expected to be a multibillion-dollar market.

However, CBD sales are not a free-for-all. For now, at least, CBD may not be marketed as a food or dietary supplement, and merchants may not make claims that CBD can treat, prevent, or cure diseases. Although laws have changed at the federal level, many US states still consider CBD a controlled substance. Furthermore, gray-market products like CBD are at a higher risk for transaction laundering.

The bottom line for now is that merchants selling CBD still present considerable uncertainty. Payment facilitators looking to enter into this space should be diligent about tracking rules and regulatory changes.


The industrial chemical 2,4-dinitrophenol (DNP) is a fertilizer and pesticide that is abused by people for weight-loss purposes. Despite clear evidence of its dangers, there has been a rise in online sales of DNP as a “dietary supplement,” and many recent deaths attributed to its use.

Because DNP is among the most dangerous products being sold for weight-loss purposes today, merchants selling the chemical for human consumption frequently obfuscate their true intentions by creating websites that appear to be selling agricultural chemicals. By seeming to sell DNP for legitimate purposes, they are able to keep a merchant account.

However, fertilizer merchants selling DNP packaged as tablets or capsules should be a red flag. Ultimately, any merchants selling DNP — even ones that appear legitimate — should face careful scrutiny.

Selective Androgen Receptor Modulator (SARMs)

These chemicals, which are legal for use in research, are designed to replicate the effects of testosterone. Though SARMs were originally developed as investigational drugs by pharmaceutical companies, they have quickly become popular as performance-enhancing products among bodybuilders and other athletes due to the perception that there is a lower risk of side effects than anabolic steroids.

There has been an increase in dietary supplements containing SARMs such as Ostarine, Andarine, and Testolone. These substances have been subject to heightened scrutiny from government agencies, citing health risks such as liver toxicity and increased risk of heart attack and stroke. Both the FDA and Health Canada consider SARMs to be unapproved drugs that have not been reviewed for safety and effectiveness.

What is the best way to spot SARMs? Payment facilitators should watch out for websites selling “research chemicals,” and should check the ingredients of all products that supplement merchants market for use in bodybuilding.


SARMs aren’t the only trend in dangerous and illicit products used for bodybuilding and body shaping. Synthol, which has been around for years but has surged in popularity recently, is an injectable used by bodybuilders to boost the cosmetic appearance of muscles.

When injected, the oil expands and hardens inside the body, resulting in a rocklike texture and appearance. Because it is typically marketed online as “posing oil” to be used topically, synthol frequently passes under the radar of payment facilitators and e-commerce platforms.

The FDA has not approved synthol or any dermal fillers for large-scale body contouring or for implantation into tendons, ligaments, or muscles. This lack of regulation poses major risks for those who inject it, but it still remains popular with bodybuilders looking for quick, dramatic changes in appearance.


Most merchants selling synthol should raise a red flag, especially if they sell the product exclusively. Product descriptions of “painless technology” or “pharmaceutical-grade ingredients” may warrant closer scrutiny. If merchants offer “discreet shipping,” that also is a cause for concern.

Apetamin is an unapproved drug marketed as a vitamin supplement for targeted weight gain — sometimes called getting “slim thick.” It contains cyproheptadine, an active pharmaceutical ingredient available only in prescription drugs in the US.

Cyproheptadine is an antihistamine used to relieve allergy symptoms such as watery eyes, runny nose, sneezing, hives, and itching. A side effect of the drug is increased appetite and, as a result, it has been used in the treatment of anorexia and severe malnutrition. This side effect has also sparked a trend for otherwise healthy people, mostly women, to misuse Apetamin for cosmetic purposes — for targeted weight gain.

Apetamin, which is sold as a syrup and as tablets in bright orange packaging, is often featured on social media and blogs as a wellness product, frequently positioned alongside cosmetic tutorials and fitness tips. For this reason, consumers can easily confuse it for a dietary supplement.

Check back with PaymentFacilitator.com for more in our series on high-risk trends, including merchants engaged in fraud and scams, and merchants posing reputational risk.