Global Financial Integrity

GFI header image

GFI Calls on Multilateral Leaders to Address COVID-19 Vaccine Integrity


Seth Berkley
CEO of Gavi, The Vaccine Alliance Geneva, Switzerland

Kristalina Georgieva
Managing Director, The International Monetary Fund Washington, DC

Tedros Adhanom Ghebreyesus
Director-General, World Health Organization Geneva, Switzerland

David R. Malpass
President, The World Bank Washington, DC

Ngozi Okonjo-Iweala
Director-General, World Trade Organization Geneva, Switzerland


Dear Dr. Berkley, Dr. Georgieva, Dr. Ghebreyesus, Mr. Malpass and Dr. Okonjo-Iweala,

We write to you as an organization that has focused for the last 15 years on illicit trade, trade misinvoicing, illicit financial flows and their impact on developing countries. As such, we call on your organizations to create a Working Group on Vaccine Integrity to address the factors that have led to fraud and illegal trade in Covid-19 vaccines. Given that your organizations focus on the nexus of global health, trade and development it is imperative that a coordinated response be established to check the proliferation of counterfeit vaccines. We appreciate that your organizations are already taking some actions in this area. We now call on you to build on this by taking the following steps to address this challenge:

  • Increase efforts to detect and disrupt the production of counterfeit vaccines, diagnostic and protective equipment and treatments for Covid-19.
  • Ensure that intellectual property rights are not applied in ways that limit access to Covid-19 vaccines.
  • Increase capacity for developing country customs departments to identify more quickly rogue shipments of vaccines and therapeutics.
  • Provide funding for a global public education campaign to warn against bogus vaccines, medicines and equipment and to build confidence in the safety and efficacy of approved therapies.
  • At the fall meetings of the IMF and World Bank, hold a panel discussion on progress made and remaining challenges in order to ensure legitimate vaccines are provided in equitable numbers to people of all nations.

As you know, Covid-19 has put a great burden on the world’s health systems, most notably those in developing and emerging market countries, which must be remedied. Further, the World Bank notes that Covid-19 has pushed approximately 100 million people into extreme poverty, and the G-20 has said that corruption and fraud in the delivery of Covid-19 related medical products is on the rise.

Additionally, as Covid-19 vaccines and personal protective equipment are being distributed, the illicit trade in these preventatives is increasing, for example with instances of dark market vaccines in Mexico as well as many other nations. Indeed, Kenya has stopped the private importation of vaccines due to the level of counterfeiting. Recently, CheckPoint Research noted that there are some 1,200 advertisements for vaccines on the dark web and that this type of activity is “booming.”

Much of this fraudulent advertising is due to the fact that developing and emerging market countries do not have access to vaccines. While there have been an estimated 700 million vaccines provided worldwide, Africa, for example, accounts for just 2 percent of the total. Latin America, Asia and other regions also lag behind the United States and Europe in the number of citizens who have been vaccinated.

We look forward to working with your organizations to enhance financial and trade integrity and to address the issues of fraud and counterfeit Covid-19 vaccines, medicine and equipment.

With best regards,

Lord Daniel Brennan, QC

Dr. Rafael Espada, Former Vice President of Guatemala
Vice Chair

Huguette Labelle, CC OOnt

Raymond Baker, Founder – Global Financial Integrity

Ambassador Segun Apata, Chairman – Nigeria Bottling Company
Board Member

Leonard McCarthy, Principle – LFMcCarthy Associates, Inc.
Board Member

John Cassara, Anti-money laundering expert
Board Member

Caroline Kende-Robb, Senior Adviser – Africa Centre for Economic Transformation
Board Member

Tom Cardamone
President & CEO