Indeed, as we saw in the recent-ish fact checking failure by the New Yorker about the "rent-a-family" business in Japan: https://newrepublic.com/article/160595/new-yorker-japan-rent...

From the article:

>An emerging theme in both controversies is that there is a fatal chink in the armor of even the most rigorous fact-checking process—that it is especially vulnerable to a naked betrayal of trust by an author or source. There is only so much a fact-checker can do if someone is intent on telling lies, particularly when the stakes are so low [...]