One of my clients/friends recently approach me with a prescription drug marketing opportunity. He has a list that I will promote to via email and get a percentage of the profits. He came into possession of a very large list of customers who have purchased prescription painkillers(non-controlled tramadol) from a now defunct online pharmacy. Many members of that pharmacy network have been federally indicted and are now in trial. This includes the doctors, pharmacy owners(the real world pharmacy which fulfilled orders), and several website operators. The network was shut down because federal agents were able to to purchase controlled substances without the proper procedures being followed(or so it's claimed, there has been no official verdict yet), although it also may be in part to the non-controlled substances being purchased without a prescription. Sites in the network basically operated by taking orders and requiring customers to fill out a questionnaire, which was then passed through a doctor who would decide if the prescription would be given. How legitimate all this was I can't say for sure until the trial is done. Anyway, as of right now we are considering promoting products from a provider who sells tramadol(but no controlled substances) to this list. Though the provider uses much the same questionnaire method that got the initial pharmacy network operators in trouble. We may also consider another provider who follows the law much more closely and/or just promote alternative non-medical products to this list. My main concerns are: 1. How do liabilities work in this case? My friend runs the site and I simply run the email campaigns to the list. He does not run the pharmacy, write prescriptions or anything else. That is done through the provider we ultimately select. Am I an accomplice to any of this by running email campaigns? 2. Are there any legit providers and or RX affiliate programs that have a long history of proper practices? Would we have any liabilities if they go under(from what I've researched so far only people who operate a website are under direct risk if any problems arise)? 3. Are there any significant long term risks in this business? I don't know much about RX affiliate programs, but it seems like a few have been in business for a while. I would highly appreciate anyone with experience in RX to answer.