In 1997, following consumer research and public comments, the FTC published an Enforcement Policy Statement on U.S. Origin Claims to guide marketers and manufacturers that want to make an unqualified Made in USA claim under...more
9/4/2025
/ Advertising ,
Compliance ,
Corporate Counsel ,
Country of Origin ,
Enforcement Actions ,
False Advertising ,
Federal Trade Commission (FTC) ,
Final Rules ,
Labeling ,
Manufacturers ,
Product Labels ,
Regulatory Requirements ,
Unfair or Deceptive Trade Practices
In March 2025, Office of the Attorney General for the State of New York introduced the Fostering Affordability and Integrity Through Reasonable (“FAIR”) Business Practices Act in the State Senate and State Assembly. The...more
9/2/2025
/ Abusive Acts ,
Advertising ,
Anti-Fraud Provisions ,
Antitrust Provisions ,
Enforcement Actions ,
False Advertising ,
Federal Trade Commission (FTC) ,
Fees ,
Fraud ,
General-Business ,
New York ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
State Attorneys General ,
Statutory Damages ,
Unfair or Deceptive Trade Practices
The Federal Trade Commission recently enacted the Made in USA Labeling Rule and updated its “Complying with the Made in USA Standard” business guidance. Both reinforce the “all or virtually all” standard...more
8/7/2025
/ Advertising ,
Compliance Management Systems ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Made in the USA ,
Manufacturers ,
Penalties ,
Product Labels ,
Regulatory Requirements ,
Supply Chain ,
Unfair or Deceptive Trade Practices
In 2024, FTC compliance lawyer wrote about the first case where the Federal Trade Commission charged a gig work company for allegedly misleading consumers about the money they could make on the company’s platform and...more
7/29/2025
/ Business Opportunities ,
Compliance ,
Consumer Protection Laws ,
Disclosure Requirements ,
Enforcement Actions ,
False Advertising ,
Federal Trade Commission (FTC) ,
Fraud ,
Gig Economy ,
Penalties ,
Scams ,
Settlement
On June 18, 2025, the New York State Attorney General announced that her office stopped an allegedly fraudulent cryptocurrency investment scam that targeted hundreds of Russian-speaking New Yorkers in Brooklyn and across the...more
6/19/2025
/ Advertising ,
Consumer Protection Laws ,
Cryptocurrency ,
Enforcement Actions ,
Financial Crimes ,
Fraud ,
Investigations ,
Investment ,
Investors ,
New York ,
Scams ,
Social Media ,
State Attorneys General
On March 31, 2025, the White House announced that President Donald J. Trump signed an Executive Order designed “to protect fans from exploitative ticket scalping and bring commonsense reforms to America’s live entertainment...more
As contemplated in December 2024, the Federal Trade Commission’s operations during the first two months under the second Trump Administration have been chaotic. Unsurprisingly, the policy focus appears to be de-regulation...more
On March 10, 2025, the Director of the Federal Trade Commission’s Bureau of Consumer Protection published a blog entry on the FTC’s website entitled “Did your business receive a CID? The FTC means business.”...more
On the eve prior to its effective date, the FCC’s One-to-One Consent Rule that sought to redefine the meaning of "prior express written consent" under the Telephone Consumer Protection Act, was postponed for one year by order...more
1/27/2025
/ Administrative Procedure Act ,
Compliance ,
Consent ,
Consumer Protection Laws ,
Enforcement Actions ,
FCC ,
Prior Express Consent ,
Robocalling ,
Rulemaking Process ,
TCPA ,
Telecommunications
President-elect Donald Trump recently announced that Republican Commissioner Andrew Ferguson will chair the Federal Trade Commission during Mr. Trump’s second administration. Commissioner Ferguson is also a known critic of...more
12/16/2024
/ Enforcement Actions ,
Federal Trade Commission (FTC) ,
Fraud ,
Investigations ,
No-Hire/No-Solicitation Agreements ,
No-Poaching ,
Nominations ,
Non-Compete Agreements ,
Penalties ,
Privacy Laws ,
Regulatory Agenda ,
Telemarketing ,
Telemarketing Sales Rule ,
Trump Administration
The FTC often initiates enforcement actions seeking to hold companies responsible for consumer injury caused by others or in which they directly participated in the misconduct. FTC CID and investigation attorney previously...more
10/25/2024
/ Advertising ,
Compliance ,
Credit Cards ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Financing ,
Fraud ,
Lead Generators ,
Liability ,
Multi-Party Litigation ,
Robocalling ,
Telemarketing Sales Rule ,
VoIP
On August 14, 2024, the Federal Trade Commission announced a Final Rule combatting bogus consumer reviews and testimonials by prohibiting their sale or purchase. The Rule allows FTC lawyers to strengthen enforcement, seek...more
8/14/2024
/ Artificial Intelligence ,
Compensation ,
Corporate Counsel ,
Deceptive Intent ,
Disclosure Requirements ,
Enforcement Actions ,
Fake Reviews ,
False Advertising ,
Federal Bans ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
FTC Act ,
Incentives ,
Misrepresentation ,
Penalties ,
Social Media ,
Solicitation ,
Testimonial Statements
The FTC has initiated a number of investigations and enforcement actions in recent years holding companies responsible for consumer injury caused by others or in which they directly participated in the misconduct.
For...more
5/20/2024
/ Enforcement Actions ,
False Advertising ,
Federal Trade Commission (FTC) ,
Fraud ,
Investigations ,
Lead Generators ,
Liability ,
Marketing ,
Misleading Statements ,
Third-Party Liability ,
Unfair or Deceptive Trade Practices ,
VoIP
The Federal Trade Commission and the U.S. Department of Health and Human Services' Office for Civil Rights are cautioning hospitals and telehealth providers about the privacy and security risks related to the use of online...more
7/31/2023
/ Breach Notification Rule ,
Data Privacy ,
Data Security ,
Department of Health and Human Services (HHS) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
FTC Act ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Hospitals ,
Investigations ,
Mobile Apps ,
OCR ,
PHI ,
Risk Assessment ,
Telehealth ,
Third-Party ,
Tracking Systems ,
Unauthorized Disclosure ,
Websites
The FTC continues to issue Notices of Penalty Offenses concerning FTC Endorsement Guide violations to digital advertisers and marketers, both alone and in conjunction with the issuance of FTC Civil Investigative Demands....more
12/9/2022
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Advertising ,
Civil Monetary Penalty ,
Disclosure Requirements ,
Enforcement Actions ,
Fake Reviews ,
Federal Trade Commission (FTC) ,
Fraud ,
FTC Act ,
FTC Endorsement Guidelines ,
SCOTUS ,
Unfair or Deceptive Trade Practices
The comment period on the FTC’s proposed rule regarding the use of endorsements and testimonials in advertising ended September 26, 2022.
The Request for Comment approved by the Federal Trade Commission in May 2022 sought...more
9/27/2022
/ Advertising ,
Credibility ,
Deceptive Intent ,
Disclosure Requirements ,
Endorsements ,
Enforcement Actions ,
Fake Reviews ,
Federal Trade Commission (FTC) ,
FTC Act ,
FTC Endorsement Guidelines ,
Liability ,
Misrepresentation ,
Online Reviews ,
Penalties ,
Proposed Rules ,
Social Media ,
Testimonial Statements
A Federal Trade Commission Civil Investigative Demand is an administrative subpoena utilized by the Federal Trade Commission (and other regulatory agencies, such as a state Attorney General) to obtain documentary materials...more
9/1/2022
/ Advertising ,
Bureau of Consumer Protection ,
CID ,
Code of Federal Regulations (CFR) ,
Defense Strategies ,
Due Diligence ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Filing Deadlines ,
FOIA ,
Information Technology ,
Investigations ,
Marketing ,
Meet and Confer ,
Rules of Practice ,
SCOTUS ,
Subpoenas ,
Unfair or Deceptive Trade Practices
A proposed FTC settlement that involves alleged false Made in USA representations and alleged deceptive COVID claims was recently filed by the Department of Justice on the FTC’s behalf against an individual and the two...more
8/15/2022
/ Advertising ,
Civil Monetary Penalty ,
COVID-19 Consumer Data Protection Act ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Advertising ,
Federal Trade Commission (FTC) ,
Made in the USA ,
Manufacturers ,
Product Labels ,
Product Packaging ,
Warning Letters
You received a Civil Investigative (CID) from the Federal Trade Commission related to a consumer protection matter.
Now what?...more
8/5/2022
/ Advertising ,
Anti-Competitive ,
Antitrust Investigations ,
Antitrust Provisions ,
Antitrust Violations ,
Civil Investigation Demand ,
Competition ,
Digital Platforms ,
Electronically Stored Information ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Marketing ,
Subpoenas ,
Unfair or Deceptive Trade Practices