Christopher Brazil

Minister of State for Health (Secondary Care)  

39 Victoria Street  
London  
SW1H 0EU  

 3rd July 2025  

Our ref: 

HM Coroner Louisa Corcoran  
Canolfan Rheidol  
Rhodfa Padarn  
Llanbadarn Fawr  
Aberystwyth  
Ceredigion  
SY23 3UE  

By email: 

Dear Mrs Corcoran,  

Thank you for the Regulation 28 report of 23 April 2025 sent to the Secretary of State for 
Health and Social Care about the death of Christopher Brazil. I am replying as the Minister 
with responsibility for medicines regulation.    

Firstly, I would like to say how saddened I was to read of the circumstances of Mr Brazil’s 
death, and I offer my sincere condolences to their family and loved ones. The circumstances 
your report describes are very concerning and I am grateful to you for bringing these matters 
to my attention.   

The  report  raises  concerns  over  the  sale  of  medicines  from  illegal  websites,  which  look 
legitimate  and  are  easily  found  from  simple  online  searches,  leading  to  vulnerable  and 
susceptible people being exposed to counterfeit or unsafe medications. It raises the concern 
that there are insufficient or no measures to verify patient medical history, age, or identity 
before selling the medication and drugs, that there is a lack of guidance regarding dosage, 
and  that  there  are  a  lack  of  safeguards  to  prevent  incorrect  self-diagnoses  or  misuse  by 
consumers. It also  raises  the  concern  that  it  is possible  for unlawful and  unethical  online 
pharmaceutical providers to operate and deliver to the buyer within 24 hours, meaning these 
illegal websites may be more appealing to some than lawful sources.  

The  Department  is  committed  to  making  online  prescribing  safe.  Prescribers,  whether 
working for the NHS or privately, in-person or remotely, are accountable for their prescribing 
decisions. They are expected to take account of appropriate national guidance. Prescribers 
should work with their patient and decide on the best course of treatment, with the provision 
of the most clinically appropriate care for the patient always being the primary consideration.  

 
  
  
  
  
 
  
   
  
  
  
   
   
     
 The  General  Pharmaceutical  Council  (GPhC)  sets  out  the  precautions  to  put  in  place  if 
certain medicines requiring additional safeguards are to be supplied online.  
Benzodiazepines refers to a group of drugs, most of which are controlled drugs under the 
Misuse of Use Drugs Act 1971, that are subject to additional safeguards. These include but 
are not limited to assuring that the person has provided the contact details of their regular 
prescriber, such as their GP, and their consent to contact them about the prescription; and 
that the prescriber will proactively share all relevant information about the prescription with 
other health professionals involved in the care of the person (for example their GP). Further 
information  on  this  can  be  found  here:  Guidance  for  registered  pharmacies  providing 
pharmacy services at a distance, including on the internet.   

The  above  guidance  was  updated  (February  2025)  in  response  to  concerns  relating  to 
unsafe  prescribing  and  supply  of  medicines  online  and  now  includes  strengthened 
safeguards  designed  to  prevent  people  from  receiving  medicines  that  are  not  clinically 
appropriate for them and may cause them harm. Specifically, the February 2025 guidance 
sets out what to include in a risk assessment when prescribing services are involved, this 
includes  considering  how  the  diverse  needs  of  people  using  pharmacy  services  are 
identified, and how staff get users’ valid consent (for example, how staff assess the mental 
capacity of users). The guidance also sets out strengthened safeguards that should be in 
place  before  supplying  certain  medicines  (those  requiring  additional  safeguards,  such  as 
benzodiazepines) online. For example, it states that a prescriber should not base prescribing 
decisions  on  the  information  provided  in  a  questionnaire  alone.    Instead,  the  prescriber 
should independently verify the information the person provides and get the information they 
need  to  support  their  prescribing  decisions.  This  could  be  through  timely  two-way 
communication with the person, accessing the person’s clinical records, or contacting the 
person’s  GP,  their  regular  prescriber,  or  a  third-party  provider.  The  guidance  also 
emphasises the need for a robust process to check the identity of individuals before making 
prescribing decisions.  

GPhC’s guidance also clarifies the expectation on those providing digital services to ensure 
their digital platform is structured in such a way that it cannot mislead the public in any way. 
Service users should not be misled about the identity of the pharmacies involved in providing 
services,  and  pharmacies  should  provide  transparent  information  on  digital  platforms, 
including their GPhC registration number.  

To  ascertain  further  details  about  procedures  followed  by  the  provider  that  prescribed  Mr 
Brazil’s  medication,  you  could  directly  approach  the  GMC  and  GPhC  who  may  have 
responsibility for their regulation.   

In a situation where an online provider acts unlawfully, the General Pharmaceutical Council 
(GPhC)  and  other  professional  regulators,  Care  Quality  Commission  (CQC)  and  the 
Medicines  and  Healthcare  products  Regulatory  Agency  (MHRA)  have  the  powers  to 
investigate and take action against prescribers, products and suppliers who do not comply 
with legislation and national guidance. I would like to assure you that regulators have my full 
support to crack down on any services putting people in danger.  

  
 The  MHRA,  acting  on  behalf  of  the  Secretary  of  State  for  Health,  is  responsible  for  the 
regulation  of  medicines  and  medical  devices  in  the  UK  by  ensuring  they  work  and  are 
acceptably  safe.  This  includes  applying  the  legal  controls  on  the  retail  sale,  supply  and 
advertising of medicines which are set out in the Human Medicines Regulations 2012. These 
regulations also apply to medicines advertised, sold or supplied via the internet.     

The sale and supply of unregulated medicinal products is a global problem. Online portals 
play a significant role in transnational medicines crime and many websites proliferate across 
the internet. Currently, there is no legal mechanism for UK law enforcement to seize control 
of illicit overseas domains or compel internet registrars to suspend them. Gaining regulatory 
compliance can be a difficult and sometimes impossible process, especially when domains 
are registered beyond the reach of UK jurisdiction.   

Public  safety  is  the  number  one  priority  for  the  MHRA  and  its  Criminal  Enforcement  Unit 
works hard to prevent, detect and investigate illegal activity involving medicines and medical 
devices. Last year, the MHRA and its partners seized millions of doses of illegally traded 
medicines. These products  included prescription-only anti-anxiety medicines,  opioids  and 
sleeping pills, and falsified and unlicensed lifestyle products used in the treatment of erectile 
dysfunction, hair loss and weight loss. It also disrupted thousands of links to websites and 
social media pages selling medical products to the public illegally.  

The MHRA also works closely with web-based sales platforms and the internet industry to 
identify and remove non-compliant medicines and medical devices where possible. Recent 
collaboration  with  one  well-known  online  marketplace  allowed  the  use  of  technology  to 
identify and block more than 1.5 million unregulated medicines and medical devices before 
they could be advertised to the public.   

Through  a  combination  of  public  empowerment,  technological  innovation,  traditional 
methods of law enforcement and close collaboration with partners, the MHRA is constantly 
working to develop new and innovative ways to tackle the online trade in illegal medicines. 
Some of these future criminal countermeasures will include:  

•  Enhanced collaboration with search engine and UK internet service providers (ISPs) 

aimed at blocking harmful content through targeted ISP-filtering.  

•  Collaboration  the  Office  of  Communications  (Ofcom)  to  explore  fresh  preventative 
opportunities presented by the Online Safety Act, which created new rules for social 
media companies and search engine providers.  

•  Boosted  collaboration  with  UK  Border  Force,  allowing  the  MHRA  to  grow  its 
operational footprint at the border and increase the seizure rates of illegally trafficked 
medicines.  

•  The use of cutting-edge technology to identify, track and seize the proceeds of crime, 

including cryptocurrency.  

•  Rollout  of  an  online  service  that  will  allow  users  to  check  if  a  website  selling 

pharmaceuticals has been deemed fraudulent by the MHRA.   

 • 

Implementation of a web-based reporting scheme allowing users to report suspicious 
websites, online marketplaces and social media listings to the MHRA.   

•  Collaboration  with  UK  banking  and  payment  providers  to  disrupt  the  payment 
mechanisms used by websites illegally supplying prescription only medicines.  

•  The  use  of  Artificial  Intelligence  to  proactively  identify  illicit  internet  domains  for 

enforcement action.  

•  Continued commitment to enhancing collegiate working across internet infrastructure 
community, including private sector and international law enforcement partners.  

The  MHRA  also  seeks  to  identify  individuals  involved  in  unlawful  activity  and,  where 
appropriate, prosecute those who put public health at risk.  

The MHRA’s Fake Meds campaign https://fakemeds.campaign.gov.uk/ encourages people 
in  the  UK  who  buy  medication  online  to  take  steps  to  ensure  they  only  use  safe  and 
legitimate sources. It also encourages people to report suspicious medicinal products and 
adverse side effects via its Yellow Card scheme https://yellowcard.mhra.gov.uk/.   

The Home Office, including the police and other UK law enforcement agencies, is the lead 
department for tackling the misuse of controlled drugs in the UK.  

The efforts of the MHRA and its partners have led to more medicines being seized than ever 
before,  significant  custodial  sentences  for  offenders,  the  forfeiture  of  criminal  profits,  and 
considerable success in disrupting illegal online trading.   

I hope this response is helpful. Thank you for bringing these concerns to my attention.    

Yours sincerely,   

Minister of State for Health and Secondary Care

Secretary of State for Science, Innovation 
and Technology 
100 Parliament Street 
London SW1A 2BQ 

www.gov.uk/dsit 

17 June 2025 

Reference: 

Dear Mrs Corcoran,  

Thank you for the opportunity to respond to this Report to Prevent Future Deaths, regarding the tragic 
death of Mr. Christopher Brazil. I was deeply saddened to read about the circumstances surrounding 
Christopher’s death and would like to extend my deepest condolences to his family and friends for their 
loss.   

In your letter, you raise concerns around unregulated and unlawful websites offering prescription only 
medicines and controlled drugs. These matters of concern are largely within the remit of the Medicines 
and Healthcare products Regulatory Agency (MHRA), given their responsibility for the regulation of 
medicines and devices in the UK. I understand that they are responding to you separately outlining their 
approach. Additionally, MHRA have informed my department that they have already taken enforcement 
action on both websites referenced in your report and are seeking to stop UK users being able to 
access such sites. One of the websites is subsequently offline, and the other is in the process of being 
taken offline to protect the public from the illegal sale of medicines. 

The government recognises that the internet can sometimes be a gateway to content which can lead to 
devastating consequences. As the Secretary of State for Science, Innovation and Technology, I am 
responsible for the Online Safety Act (the ‘Act’) which received Royal Assent in 2023. The Act lays the 
foundation for strong protections against illegal content for all users, and the government is committed 
to working with Ofcom, the independent regulator, to ensure it is implemented quickly and effectively. 
The new laws apply to search services and all companies that allow users to post content online or to 
interact with each other. This includes a broad range of websites, apps and other services, including 
social media services, consumer cloud storage sites, video sharing platforms, online forums, dating 
services, and online instant messaging services. 

As the concerns you set out in your letter are around content found via online searches, I will focus on 
the duties under the Act which are relevant to search services. The Act’s illegal content safety duties 
require all in-scope search services to operate their service using proportionate systems and processes 
designed to minimise the risk of all users from encountering search content which is priority illegal 
content via their service. In practice, this could look like removing results for sites that are known to host 
illegal content. The relevant priority offences are set out in Schedule 7 and include content facilitating 
the unlawful supply of controlled drugs, as per the Misuse of Drugs Act 1971.  Search services must 
also take or use, where proportionate, user support measures which might for example, signpost users 
towards sources of support. These duties will play a key role in protecting all users - children and adults 
- from encountering such search content. The illegal harms codes of practice came into force in March. 
As a result, search services must have measures in place to comply with their duties under the Act and 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
         
 
 
 
 
 
 
 
 
 Ofcom can now enforce against non-compliance. Within the first month of the duties coming into effect, 
Ofcom launched several enforcement programmes to monitor compliance with the regime. 
Implementation of the Act represents a huge step forward in online safety.   

Whilst Christopher was an adult when he was able purchase medicines from illegal websites, I would 
like to touch on the Act’s additional provisions for children, as we know that the impact of harmful 
content and activity online can be particularly damaging for young people. Search services likely to be 
accessed by children need to take steps to protect them from content which is legal but nonetheless 
harmful. In-scope services that are likely to be accessed by children will have a duty to take steps to 
prevent children from encountering the most harmful content that has been designated as ‘primary 
priority’ content. This includes pornography and content that encourages, promotes, or provides 
instructions for self-harm, eating disorders, or suicide.  Online services must also put in place age-
appropriate measures to protect children from ‘priority’ content. This includes content that encourages 
or depicts serious violence or injury, or dangerous stunts or challenges and content that encourages 
ingestion, inhalation or exposure to harmful substances. From July, the child online safety regime will 
be fully in force. 

As the independent regulator for the Act, Ofcom have a range of enforcement powers which it can use 
against non-compliant regulated services, including instructing services to take steps to return to 
compliance, issuing fines of up to £18 million or 10% of qualifying worldwide revenue. It can also apply 
to the courts to initiate business disruption measures, which require third party ancillary and access 
services to withdraw their services from the non-compliant operator (and can result in ‘blocking’). 

Whilst the majority of the matters of concern raised in your report are not directly within the remit of my 
department, I would like to thank you again for drawing this to my attention and I hope that this 
response is useful in setting out where the Online Safety Act will offer significant new protections 
against illegal content and harmful material for children online. The government will continue to keep 
online safety policy under review and identify areas where we can build on the Act, so it is important for 
me to be made aware of online safety related Reports to Prevent Future Deaths 

Yours sincerely, 

Secretary of State for Science, Innovation and Technology