Federal Trade Commission

October 18, 2023

Protecting 

Older 

Consumers 

2022–2023

A Report of the

Federal Trade Commission 
Protecting

Older Consumers

2022–2023

A Report of the Federal Trade Commission

October 18, 2023

FEDERAL TRADE COMMISSION

Lina M. Khan, Chair

Rebecca Kelly Slaughter, Commissioner

Alvaro M. Bedoya, Commissioner
Contents

I. Introduction......................................................................................................1

II. FTC Enforcement Activities Affecting Older Consumers...........................2

A. Enforcement Actions.....................................................................................................3

B. Case Resolutions............................................................................................................8

C. Other Enforcement Highlights.......................................................................................9

1. COVID-19 Demand Letters..........................................................................................9

2. Consumer Monetary Relief.........................................................................................11

3. Criminal Liaison Unit.................................................................................................16

4. Referrals to the FBI’s Recovery Asset Team .............................................................17

D. FTC Efforts To Protect Older Americans Remain Handicapped After AMG.............18

E. Strategies to Provide Additional Tools Post-AMG to Enhance FTC Enforcement 

Efforts.........................................................................................................................18

III. Outreach and Education Activities..............................................................20

A. Pass It On Education Campaign..................................................................................20

1. Outreach to Older Adults............................................................................................21

2. Pandemic Response ....................................................................................................24

IV. Developing Effective Strategies to Protect Older Consumers...................24

A. Research and Data Analysis........................................................................................24

1. Consumer Sentinel Reports from Older Adults..........................................................25

2. Hearing Directly from Older Adults About FTC Impersonators................................40

B. Coordinated Efforts to Protect Older Consumers........................................................41

C. Scams Against Older Adults Advisory Group ............................................................42

V. Conclusion.......................................................................................................45
FEDERAL TRADE COMMISSION FTC.GOV 1

I. Introduction

The Federal Trade Commission (“FTC” or “Commission”) serves as the government’s leading 

consumer protection agency and is charged with protecting consumers from unfair and deceptive 

acts and practices in the marketplace. One of the FTC’s top priorities is protecting older adults,1

and it uses a variety of methods to do so.2 First, the FTC files enforcement actions and returns 

money to consumers when possible.3 This year, the FTC has brought enforcement actions 

regarding schemes involving deceptive sweepstakes, debt relief scams, alleged COVID-relief 

supplements or addiction recovery services, fraudulent timeshare exit services, chargeback 

mitigation, tech support services, and illegal robocalls. The FTC’s past enforcement efforts have

also resulted in relief of more than $285 million to consumers of all ages distributed in this last 

fiscal year. In addition, the FTC held a hearing on a proposed rule prohibiting government and 

business impersonation, which if finalized, will bolster the FTC’s ability to return money to 

consumers in light of the impact of the Supreme Court’s ruling in AMG Capital Mgmt. v. FTC.

4

Second, the FTC engages in outreach and education activities to reach older adults throughout 

the United States. The FTC’s continued innovative approach helps alert older adults to common 

types of fraud and resources to protect themselves. As the population of older adults grows, the 

1 This report refers to persons 60 and older when using the terms “older adults” or “older consumers” to be 

consistent with the requirements in Section 2(1) of the Elder Abuse Prevention and Prosecution Act, which 

references Section 2011 of the Social Security Act (42 U.S.C. § 1397j(5)) (defining “elder” as an individual age 60 

or older).

2 This report focuses on the Bureau of Consumer Protection’s work to protect older adults. The FTC’s Bureau of 

Competition also serves older adults through its work in various sectors of the economy, such as health care, 

consumer products and services, technology, manufacturing, and energy. The primary drafters of this staff report are 

Sophia Siddiqui and Patricia Hsue, Division of Marketing Practices; Emma Fletcher, Division of Consumer 

Response and Operations; Bridget Small, Division of Consumer and Business Education; and Maria Del Monaco, 

East Central Region. Additional acknowledgement goes to Kati Daffan, Division of Marketing Practices; Maria 

Mayo, Patti Poss, Christopher Stone, Nicole Christ, and Vincent Law, Division of Consumer Response and 

Operations; Jennifer Leach, Karen Hobbs, Kira Krown, Colleen Tressler, and Marlena Patterson, Division of 

Consumer and Business Education; Devesh Raval, Bureau of Economics; Sarah Waldrop, Division of Enforcement; 

Karen Mandel and Christine DeLorme, Division of Advertising Practices; and Summer Law Clerks Kristin Elnikar, 

Molly Gillespie, and Choteau Kammel. This report reflects the work of staff throughout the Federal Trade 

Commission’s Bureau of Consumer Protection and its Regional Offices, with much of the work stemming from the 

FTC’s Every Community Initiative. Lois C. Greisman is the FTC’s Elder Justice Coordinator. 

3 The FTC has wide-ranging law enforcement responsibilities under the Federal Trade Commission Act, 15 U.S.C. § 

41 et seq. (“FTC Act”) and enforces a variety of other laws ranging from the Telemarketing and Consumer Fraud 

and Abuse Prevention Act to the Fair Credit Reporting Act. In total, the Commission has enforcement or 

administrative responsibilities under more than 80 laws. See https://www.ftc.gov/legal-library/browse/statutes. 

4 AMG Capital Mgmt., LLC v. FTC, 593 U.S. ___; 141 S. Ct. 1341 (2021) (holding that Section 13(b) of the FTC 

Act does not authorize federal courts to require defendants to refund monies to consumers or give up unjust gains).

The Commission encourages Congress to enact legislation that restores the FTC’s Section 13(b) authority to provide 

redress to consumers, as set forth in Section II.D, supra. 
FEDERAL TRADE COMMISSION FTC.GOV 2

FTC’s outreach mission to help consumers spot, avoid, and report scams becomes increasingly 

important. 

Finally, the FTC conducts research and collaborates with diverse partners across the country, 

including AARP, industry, military servicemembers and veterans, and other older adult 

advocates. The FTC utilizes the information and analysis it obtains from these efforts to make 

strategic decisions on how to best tackle issues impacting older adults. For example, the FTC’s 

analysis of fraud and other reports filed by consumers nationwide helps the agency understand 

and respond to patterns and trends related to older adults, including the differences in how older 

adults in different demographic populations may experience fraud. 

The FTC submits this sixth annual report to the Committees on the Judiciary of the United States 

Senate and the United States House of Representatives to fulfill the reporting requirements of 

Section 101(c)(2) of the Elder Abuse Prevention and Prosecution Act of 2017. The report 

describes the FTC’s recent comprehensive efforts to protect older consumers. The report also 

includes, as required by law, a list in Appendix A of every administrative and federal district 

court action filed in the last year that has impacted older adults.5

II. FTC Enforcement Activities Affecting Older 

Consumers

A key cornerstone of the FTC’s efforts to protect older consumers is aggressive law 

enforcement. Nearly all FTC enforcement actions involve consumers of all ages. While the 

actual ages of people affected in a given case are typically unknown, in the Commission’s view, 

older adults are among those affected in almost every consumer protection case filed this past 

fiscal year. Therefore, Appendix A to this report lists most new enforcement actions brought by 

the FTC between October 1, 2022, and September 30, 2023. The cases listed in Appendix A 

involve a wide range of matters, including allegations regarding sweepstakes, business 

opportunity and money-making schemes, unsubstantiated product claims, timeshare exit 

services, unlawful robocalls, debt relief recovery services, tech support scams, addiction 

recovery treatments, false claims about COVID-19 treatment or prevention, and more.6

This section highlights twelve enforcement actions filed within the last fiscal year where the 

Commission noted a significant impact on older adults. It also describes other agency actions 

that affected older consumers, including case resolutions, cease and desist demand letters, 

consumer refunds, and subsequent criminal action by other agencies relating to FTC matters or 

5 The law requires the FTC Chair to file a report listing the FTC’s enforcement actions “over the preceding fiscal 

year in each case in which not less than one victim was an elder or that involved a financial scheme or scam that was 

either targeted directly toward or largely affected elders.” 

6 This list includes cases involving violations of children’s privacy laws. The perpetrators of such schemes may not 

typically target older adults, but the cases are listed because they involve large and diverse groups of consumers. 

The affected consumers may include an older parent or grandparent caring for children who go online and wish to 

protect their privacy.
FEDERAL TRADE COMMISSION FTC.GOV 3

with assistance from the FTC. Finally, this section describes the Commission’s work on a 

proposed rule prohibiting government and business impersonation, as part of its ongoing strategy 

and efforts to provide better tools to enhance its law enforcement work. 

A.Enforcement Actions

The Commission filed the following new enforcement actions in the last fiscal year that likely 

had a significant impact on older adults:

In Publishers Clearing House, the FTC charged that the company used “dark patterns” to 

mislead consumers, many of whom were older adults or lower-income, about how to enter the 

company’s well-known sweepstakes drawings and made them believe that a purchase was 

necessary to win or would increase their chances of winning.7 The FTC also charged that the 

company added surprise shipping and handling fees to the costs of products, misrepresented that 

ordering was “risk free,” used deceptive emails as part of its marketing campaign, and 

misrepresented its policies on selling users’ personal data to third parties prior to January 

2019.8 PCH agreed to settle the FTC’s charges that it violated the FTC Act and CAN-SPAM 

Act, and in June 2023 a district court approved a stipulated order requiring the company to make 

a number of key changes to its email and internet operations, including halting deceptive 

marketing practices like manipulative phrasing on its website, and requiring it to turn over $18.5 

million to the FTC to be used to refund consumers.

In Yodel Technologies, the DOJ, on behalf of the FTC, filed a complaint and proposed order 

alleging that defendants bombarded consumers with over a billion calls, including hundreds of 

millions of robocalls and calls to phone numbers on the National Do-Not-Call Registry, selling a 

variety of products and services such as medical devices, Medicare supplements, and purported 

assistance with Social Security benefits.9 The complaint alleges that defendants used soundboard 

technology in their calls and obtained consumers’ information from websites that allegedly failed 

to obtain consumers’ informed consent to receive telemarketing calls. This case is part of a 

coordinated crackdown on illegal telemarketing calls, “Operation Stop Scam Calls,” that the FTC 

led in partnership with more than 100 federal and state law enforcement agencies that resulted in 

over 180 actions targeting operations responsible for billions of calls to consumers.10 Defendants

7 Press Release, FTC, FTC Takes Action Against Publishers Clearing House for Misleading Consumers About 

Sweepstakes Entries (June 27, 2023), available at https://www.ftc.gov/news-events/news/press-releases/2023/06/ftctakes-action-against-publishers-clearing-house-misleading-consumers-about-sweepstakes-entries.

8 FTC v. Publishers Clearinghouse, LLC (PCH), No. 2:23-cv-04735 (E.D.N.Y. June 27, 2023), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3145-publishers-clearing-house-llc-pch-ftc-v; 

https://www.ftc.gov/legal-library/browse/cases-proceedings/2123074-yodel-technologies.

9 United States v. Yodel Technologies, LLC, et al., No. 8:23-cv-1575 (M.D. Fla. Jul. 14, 2023), available at 

https://www.ftc.gov/system/files/ftc_gov/pdf/001YodelComplaint.pdf. 

10 Press Release, FTC, FTC, Law Enforcers Nationwide Announce Enforcement Sweep to Stem the Tide of Illegal 

Telemarketing Calls to U.S. Consumers (Jul. 18, 2023), available at https://www.ftc.gov/news-events/news/press-
FEDERAL TRADE COMMISSION FTC.GOV 4

agreed to settle the complaint charges that they violated the Telemarketing Sales Rule, and in 

August 2023 a district court approved a stipulated order banning the defendants from engaging in 

telemarketing and ordering them to pay a $400,000 civil penalty.

In ACRO Services, the FTC settled charges against the individual operators of an alleged credit 

card debt relief scheme that took millions of dollars from consumers—often older and financially 

distressed individuals—by falsely claiming to eliminate or reduce their credit card debts.11

Defendants allegedly told consumers that they would charge consumers’ credit cards an upfront 

fee in the thousands of dollars (with some charges as high as $18,000) but that consumers would 

not actually owe this fee because it would eventually be eliminated in the program. Once 

consumers were enrolled, defendants encouraged them to cease paying their credit card bills and 

communicating with their creditors.12 In reality, according to the complaint, defendants neither 

reduced nor eliminated consumers’ credit card debts, and many consumers ended up owing their 

original debts plus thousands in additional fees and interest, being sued by their creditors, and 

seeing their credit scores drop significantly. The court order permanently bans the operators of 

this scheme from telemarketing and selling debt relief products or services, enjoins them from 

deceiving consumers about any other product or service they sell, and requires them to surrender 

certain property interests and assets to be used for possible refunds to consumers. The FTC is 

currently pursuing a default judgment against the remaining company defendants.

In Square One Development Group Inc., the Department of Justice (DOJ), on behalf of the 

FTC, and the Wisconsin Attorney General filed suit against Square One Development Group Inc. 

and related companies alleging that they sold fraudulent timeshare exit services.

13 According to 

the complaint, the defendants targeted older Americans through direct mail campaigns, luring 

consumers to high-pressure sales presentations at local hotels and restaurants. During the 

presentations, the defendants allegedly made bogus affiliation claims, deceived consumers about 

their timeshare exit options, and stoked unfounded fears about how their heirs would be affected 

if they did not act immediately.

14 The complaint further alleges that the defendants charged 

exorbitant upfront fees, which they promised to return if they were unable to secure the 

releases/2023/07/ftc-law-enforcers-nationwide-announce-enforcement-sweep-stem-tide-illegal-telemarketing-callsus. 

11 Press Release, FTC, FTC Lawsuit Leads to Permanent Ban from Debt Relief, Telemarketing for Operators of 

Debt Relief Scam (May 1, 2023), available at https://www.ftc.gov/news-events/news/press-releases/2023/05/ftclawsuit-leads-permanent-ban-debt-relief-telemarketing-operators-debt-relief-scam.

12 FTC v. ACRO Services, LLC, et al., No. 3:22-cv-00895 (M.D. Tenn. Nov. 30, 2022), available at 

https://www.ftc.gov/legal-library/browse/cases-proceedings/acro-services.

13 United States v. Square One Development Group Inc., et al., No. 4:22-cv-01243 (E.D. Mo. Nov. 21, 2022), 

available at https://www.ftc.gov/legal-library/browse/cases-proceedings/2123065-square-one-development-groupinc-et-al-us-state-wisconsin-v.

14 Press Release, FTC, FTC, Wisconsin Attorney General Take Action Against Timeshare Exit Scammers for 

Cheating Consumers Out of $90 Million (Nov. 22, 2022), available at https://www.ftc.gov/news-events/news/pressreleases/2022/11/ftc-wisconsin-attorney-general-take-action-against-timeshare-exit-scammers-cheating-consumersout-90.
FEDERAL TRADE COMMISSION FTC.GOV 5

timeshare exits within the promised time. It states that the defendants seldom succeeded in 

securing exits from the timeshares and failed to return nearly every requested refund, citing 

numerous phony reasons as to why they did not deliver the promised service. Ultimately, the 

defendants allegedly scammed consumers out of more than $90 million. The complaint seeks

civil penalties, other monetary relief, and a court order to prevent future violations.

In Global E-Trading, LLC, the FTC and the Office of the Attorney General of Florida filed a 

complaint alleging that the defendants, who operate a chargeback mitigation business known as 

“Chargebacks911,” have used misleading information to contest chargebacks on behalf of their 

merchant clients.15 Chargebacks occur when consumers dispute credit card charges with their 

banks, such as when consumers believe they have been subject to fraud or unfair business 

practices. The defendants assist merchants in disputing consumer chargebacks. According to the 

FTC, the defendants submitted misleading chargeback evidence to consumers’ banks, making it 

more likely that the chargebacks would be denied.16 The defendants also allegedly helped their 

clients wrongfully manipulate their chargeback rates to avoid fraud monitoring programs. The 

FTC and Florida Attorney General seek an order stopping the defendants’ illegal activities, and 

the Florida Attorney General seeks to secure monetary relief under Florida law, including civil 

penalties for each violation that harmed an older consumer.

In Precision Patient Outcomes, Inc., the FTC alleged that the defendants made deceptive claims 

that their dietary supplement, named COVID Resist/VIRUS Resist, could treat, prevent, or 

mitigate COVID-19.17 The supplement contained nothing more than vitamins, zinc, and a 

flavonoid. According to the FTC, the defendants stated that research and studies supported their 

claims, including statements such as “A dose of this formula a day keeps viruses away. . . and 

their variants. Take COVID resistTM daily or for pre-exposure prophylaxis (PrEP), post exposure 

prophylaxis (PEP), or as a therapeutic.” The complaint alleges that the defendants lacked a 

reasonable basis for their COVID-19 claims and misrepresented the research and studies.18 The 

FTC is seeking permanent injunctive relief, monetary relief, and a civil penalty judgment.

In XCast Labs, Inc., the DOJ, on behalf of the FTC, sued to stop a Voice over Internet Protocol 

(VoIP) provider, XCast Labs, Inc., from allegedly funneling hundreds of millions of illegal 

15 Press Release, FTC, FTC, Florida Attorney General Sue Chargebacks911 for Thwarting Consumers Who Were 

Trying to Reverse Disputed Credit Card Charges (Apr. 12, 2023), available at https://www.ftc.gov/newsevents/news/press-releases/2023/04/ftc-florida-attorney-general-sue-chargebacks911-thwarting-consumers-whowere-trying-reverse-disputed. 

16 FTC v. Global E-Trading, LLC, et al., No. 8:23-cv-00795 (M.D. Fl. Apr. 12, 2023), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/2023009-chargebacks-911.

17 Press Release, FTC, FTC Acts to Stop Deceptive COVID-19 Advertising Claims by California’s Precision Patient 

Outcomes, Inc. (Nov. 22, 2022), available at https://www.ftc.gov/news-events/news/press-releases/2022/11/ftc-actsstop-deceptive-covid-19-advertising-claims-californias-precision-patient-outcomes-inc-0.

18 FTC v. Precision Patient Outcomes, Inc., et al., No. 4:22-cv-7307 (N.D. Cal. Nov. 18, 2022), available at 

https://www.ftc.gov/legal-library/browse/cases-proceedings/2123137-precision-patient-outcomes.
FEDERAL TRADE COMMISSION FTC.GOV 6

robocalls through its network, even after receiving multiple warnings.19 The complaint alleges 

that XCast Labs received dozens of “traceback” inquiries from US Telecom’s Industry 

Traceback Group regarding suspected illegal calls that originated on XCast Labs’ network, as 

well as inquiries from law enforcement agencies about transmission of suspected illegal traffic 

on the XCast Labs network. The complaint also alleges that even after receiving these direct 

warnings, XCast Labs transmitted illegal robocalls to consumers. In addition, the FTC 

discovered that many of these suspect robocalls were part of organized campaigns designed to 

generate telemarketing leads by, for example, impersonating federal officials from the Social 

Security Administration.20 Lead generators sell the information they gather to telemarketers, who 

then use consumers’ information to pester them with even more unwanted, illegal calls. The 

complaint seeks civil penalties, other monetary relief, and a court order to prevent future 

violations.

The DOJ, on behalf of the FTC, filed three separate complaints and proposed orders against 

current and former high-level distributors for doTERRA International, LLC, a multi-level 

marketing company.21 The defendants are former registered nurse Lauren Busch, pediatrician 

Dr. Tina Wong, and nurse practitioner Eliza Johnson Bacot, all of whom allegedly used their 

healthcare expertise to bolster their product recommendations. According to the complaints, 

these distributors participated in a series of webinars during which they made baseless claims 

that the company’s dietary supplements and essential oils could effectively treat, prevent, or cure 

COVID-19.22 The stipulated orders require each defendant to pay a $15,000 civil penalty, end 

any COVID claims that are not FDA-approved, and stop making any other health-related claims 

without scientific proof.

23

In Nexway, the DOJ, on behalf of the FTC, filed suit alleging that, since August 2016, a 

multinational payment processing company, along with its CEO and chief strategy officer, 

19 FTC v. XCast Labs, Inc., No. 2:21-mc-01026 (C.D. Cal. Feb. 14, 2023), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/xcast-labs-inc-ftc-v.

20 Press Release, FTC, FTC Sues to Stop VoIP Services Provider That Assisted and Facilitated Telemarketers In 

Sending Hundreds of Millions of Illegal Robocalls to Consumers Nationwide (May 12, 2023), available at 

https://www.ftc.gov/news-events/news/press-releases/2023/05/ftc-sues-stop-voip-service-provider-assistedfacilitated-telemarketers-sending-hundreds-millions.

21 Business Blog, FTC, An Essential Truth About COVID Claims (Mar. 3, 2023), available at

https://www.ftc.gov/business-guidance/blog/2023/03/essential-truth-about-covid-claims.

22 Press Release, FTC, FTC Takes Action Against doTERRA Distributors for False COVID-19 Health Claims

(Mar. 3, 2023), available at https://www.ftc.gov/news-events/news/press-releases/2023/03/ftc-takes-action-againstdoterra-distributors-false-covid-19-health-claims.

23 United States v. Busch, No. 2:23-cv-00009 (D. Utah Mar. 1, 2023), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/doterra-busch; United States v. Wong, No. 2:23-cv-63-MRW (C.D. Cal. Jan. 10, 

2023), available at https://www.ftc.gov/legal-library/browse/cases-proceedings/doterra-wong; United States v. 

Bacot, No. 1:23-cv-00058-AT (N.D. Ga. Jan. 23, 2023), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/doterra-bacot. 
FEDERAL TRADE COMMISSION FTC.GOV 7

assisted and facilitated illegal sales and laundered credit card charges.24 The complaint alleges 

that defendants worked with telemarketers who made misrepresentations to consumers about the 

performance and security of their computers in connection with the sale of bogus technical 

support services. It also alleges defendants violated the law either by assisting and facilitating 

those illegal sales and laundering the credit card charges through their own merchant accounts, 

or by engaging in the enterprise as the ultimate sellers liable for the transactions.25 The 

defendants in the case agreed to proposed court orders that prohibit them from any further 

payment laundering and require them to closely monitor other high-risk clients for illegal 

activity. In April 2023, the FTC and DOJ announced that the defendants agreed to a total 

monetary judgment of $49.5 million, which will be partially suspended upon payment of 

$650,000 in funds for consumer redress due, in part, to an inability to pay.

In AWAREmed, the DOJ, on behalf of the FTC, filed a complaint and a proposed order against a 

medical clinic alleging it made unfounded claims about the success of its treatments.26 The 

complaint alleged that AWAREmed and its owner, Dr. Dalal Akoury, used deceptive 

advertisements that promised a 98% improvement rate in treating almost any condition. 

Specifically, defendants advertised on AWAREmed’s website that their cancer treatments would 

either lessen or eliminate cancer in most patients, and that their treatment of chronic diseases, 

including Alzheimer’s disease and Parkinson’s disease, was almost always successful. 

Defendants’ ads also promised a fast and painless recovery from various addictions, including 

everything from alcohol and opioids to food and gambling that the complaint alleged violated the 

Opioid Addiction Recovery Fraud Prevention Act.

27 The Court accepted the proposed 

settlement, which requires AWAREmed and Akoury to pay a $100,000 civil penalty and bars 

them from making future claims about cures or treatments that are unsupported by scientific 

evidence.28

24 FTC v. Nexway, No. 1:23-cv-900 (D.D.C. Apr. 17, 2023), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/1923239-x230018-nexway-inc-matter.

25 Press Release, FTC, FTC Acts to Block Payment Processor’s Credit Card Laundering for Tech Support Scammers

(Apr. 17, 2023) available at https://www.ftc.gov/news-events/news/press-releases/2023/04/ftc-acts-block-paymentprocessors-credit-card-laundering-tech-support-scammers.

26 Press Release, FTC, FTC Sues Medical Clinic and its Owner for False or Unsubstantiated Claims its Treatment 

Could Cure Addiction and Other Diseases (Mar. 16, 2023), available at https://www.ftc.gov/newsevents/news/press-releases/2023/03/ftc-sues-medical-clinic-its-owner-false-or-unsubstantiated-claims-its-treatmentcould-cure-addiction.

27 Pub. L. No. 115-271, 132 Stat. 4082 (codified in relevant part at 15 U.S.C. § 45d); Consumer Alert, FTC, Before 

You Believe Addiction or Cancer Claims, Read This (Mar. 16, 2023), available at

https://consumer.ftc.gov/consumer-alerts/2023/03/you-believe-addiction-or-cancer-claims-read.

28 United States v. Akoury, No. 2:23-cv-00026 (E.D. Tenn. Mar. 16, 2023), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/2123039-dalal-akoury-dba-awaremed-et-al-us-v.
FEDERAL TRADE COMMISSION FTC.GOV 8

B.Case Resolutions

The Commission reached resolution in three pending cases involving older adults in the last 

fiscal year.

In Raging Bull.com, the FTC settled charges against Kyle Dennis, the last remaining defendant

in a case filed in December 2020 against Raging Bull.com and related companies. The FTC’s 

complaint alleged the defendants fraudulently marketed investment-related services that they 

claimed would enable consumers to make consistent profits and beat the market.29 It also alleged 

the defendants used inflated and false earnings claims to induce consumers into signing up for 

costly and hard-to-cancel subscriptions and to pay for investment strategies. The FTC further 

alleged that Raging Bull and its owners were “bilking consumers out of millions of dollars on a 

monthly basis” and that “a number of these consumers [were] older adults, retirees, and/or 

immigrants.” In September 2023, defendant Kyle Dennis, a supposed stock trading “guru” for 

RagingBull.com, who was charged by the FTC with pitching bogus stock tips that cost 

consumers more than $40 million, agreed to settle the FTC’s charges. Under the final order, 

Dennis is permanently prohibited from making any representations about potential earnings 

without having written evidence that those claims are typical for consumers, and from making 

any false or misleading marketing claims in general.30

In ZyCal Bioceuticals Healthcare Company, Inc., the FTC settled charges that a company and 

its president deceptively claimed their products could grow bone and cartilage and relieve joint 

pain, including in persons with osteoporosis and osteoarthritis. In its complaint filed in early 

2020, the FTC alleged these claims were not substantiated by competent and reliable scientific 

evidence, and that their claims of scientific proof were false.31 The settlement bars the 

defendants from making claims about bone and cartilage growth, joint pain, and other healthrelated claims unless they are substantiated by competent and reliable scientific evidence, and 

prohibits them from misrepresenting the results of any tests, studies, and research.32 The 

defendants also must provide notice of the settlement to numerous purchasers of the products.

29 FTC v. Raging Bull.com, et al., No. 1:20-cv-3538 (D. Md. Dec. 7, 2020), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/2023073-x210014-ragingbullcom.

30 Press Release, FTC, RagingBull.com Stock Trading “Guru” Kyle Dennis Faces Permanent Injunction as Result of 

FTC Action (Sept. 8, 2023), available at https://www.ftc.gov/news-events/news/pressreleases/2023/09/ragingbullcom-stock-trading-guru-kyle-dennis-faces-permanent-injunction-result-ftc-action.

31 FTC v. ZyCal Bioceuticals Healthcare Company, Inc., et al., No. 4:20-cv-10249-TSH (D. Mass. Feb. 10, 2020), 

available at https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3133-zycal-bioceuticals-healthcarecompany-inc.

32 Press Release, FTC, FTC Order to Bar ZyCal Bioceuticals from Deceptive Health Marketing (Feb. 6, 2023), 

available at https://www.ftc.gov/news-events/news/press-releases/2023/02/ftc-order-bar-zycal-bioceuticalsdeceptive-health-marketing.
FEDERAL TRADE COMMISSION FTC.GOV 9

In Romero, the FTC obtained summary judgment in its favor in a case filed in June 2021 against 

Frank Romero, doing business as Trend Deploy.33 The complaint stated that Romero acted on 

consumers’ fears during the COVID-19 pandemic and deceptively advertised quick delivery of 

N95 masks and other protective devices.34 The FTC further stated that Romero rarely if ever 

shipped the devices his websites offered for sale, failed to offer refunds for consumers’ 

purchases required by the FTC’s Mail Order Rule, and failed to notify customers of shipping 

delays. The court order permanently enjoins Romero from selling or offering for sale any 

protective goods or services, imposes a civil penalty, and enters a monetary judgment.

C.Other Enforcement Highlights

Other FTC enforcement highlights include the issuance of cease and desist demand letters, the 

provision of consumer redress to consumers in cases previously brought by the FTC, and 

criminal actions by other agencies that relate to prior FTC matters or where the FTC provided 

assistance.

1. COVID-19 Demand Letters

COVID-19 has had a particularly devastating impact on the health and finances of older adults. 

Throughout the pandemic, the FTC has taken action to stop many false and unsubstantiated 

claims about COVID-19 treatment or prevention that exploit consumers’ fear of the disease and 

its effects. In some circumstances, to swiftly address troubling claims related to COVID-19, the 

FTC has sent cease and desist demand letters to companies and individuals. These letters warn

recipients that their conduct is unlawful, and that they can face serious legal consequences, such 

as a federal lawsuit and civil penalties, if they do not immediately cease and desist from 

engaging in such conduct.35

During the last fiscal year, the FTC sent five cease and desist demand letters to companies that

allegedly violated the law by making false or unsupported claims about their products’ ability to 

prevent, treat, or cure coronavirus disease. All of these letters were sent jointly with the FDA. 

The unsubstantiated claims included references to clinical trials or studies touting the products’ 

effectiveness against COVID-19, as described below. 

• In October 2022, the FTC sent a cease and desist demand letter to Lakpura LLC 

challenging its claims that various ayurvedic and other products could prevent or treat 

COVID-19. The company claimed on its website that one of its products was 

33 Press Release, FTC, At FTC’s Request, Florida District Court Permanently Bars Deceptive COVID-19 PPE 

Marketer from Selling Any Protective Goods or Services to Consumers (June 5, 2023), available at 

https://www.ftc.gov/news-events/news/press-releases/2023/06/florida-district-court-permanently-bars-covid-19-ppemarketer-from-selling-goods-services.

34 FTC v. Romero, No. 5:21-cv-00343 (M.D. Fla. June 30, 2021), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/2023128-trend-deploy.

35 Information about the letters sent by the FTC can be found at https://www.ftc.gov/newsevents/features/coronavirus/enforcement/warning-letters. 
FEDERAL TRADE COMMISSION FTC.GOV 1 0

“[A]pproved by the ayurvedic Department of Health, an immune-enhancing drink for the 

COVID-19 virus based on ancient indigenous prescription and treatment,” and 

encouraged consumers to purchase Ceylon black teas by stating that: “While still in its 

preliminary findings, it has been noted that according to the latest research, the presence 

of theaflavin, a polyphenolic compound in black tea is said to have a medicinal value; 

thus acting as an inhibitor against several viruses . . . even SARS-related viruses like 

COVID-19.”

• In November 2022, the FTC sent a cease and desist demand letter to Alternative Health 

Distribution LLC (d/b/a CannaAid) challenging its promotion of cannabidiol (CBD) 

products to treat and prevent COVID-19. The company made claims on its website such 

as:

“HOW DOES CBD HELP TO FIGHT AGAINST COVID-19? . . . Recent analyses from

numerous preliminary in vitro and animal studies have shown that cannabinoids in hemp, 

specifically CBD, can significantly reduce COVID-19’s ability to infect new cells –

limiting inflammation in the lungs and possibly improving a patients’ quality of life 

during severe COVID-19 infection.”

• In January 2023, the FTC sent a cease and desist letter to PharmaCanna challenging its 

advertising of cannabinoid products to treat and prevent COVID-19. The company made 

claims on its website and social media including: “CBDefense 2000 - Virus Protective 

Formula . . . This revolutionary virus fighting product contains the two cannabinoids, 

CBDa & CBGa, that has been shown through a published study to keep covid from 

infecting human cells,” and “Our CBDefense 2000, anti-covid formula, is Now 

Available.”

• In January 2023, the FTC sent a cease and desist letter to PureCraft LLC challenging

claims that its CBD products could treat and prevent COVID-19. The company made the 

claims on its website including: “Early results show that therapeutic doses of CBD do 

have a protective effect against COVID,” and “According to a March 2022 article in 

Frontiers in Immunology, CBD has been shown to decrease the severity of COVID. It’s 

primarily doing this by counteracting the body’s inflammatory response to the SARSCoV-2 virus . . . .”

• In January 2023, the FTC sent a cease and desist letter to Medical Mikes, Inc. challenging

its promotion of CBD products to treat and prevent COVID-19. The company made 

claims on its website that included: “widely circulated research indicated that highly 

potent oral CBD inhibits Covid infection in human lung cells and mice,” and “Study 

investigators found that, of hemp’s hundreds of cannabinoids, CBDa and CBGa exhibited 

the most powerful ability to inhibit the Covid protein from seizing human cells. Even 

more profound, these minor cannabinoids reduced viral infection loads (still, in a petri 

dish) by an astounding 50%.”
FEDERAL TRADE COMMISSION FTC.GOV 1 1

2. Consumer Monetary Relief

In the last fiscal year, FTC enforcement actions have resulted in relief of more than $285 million 

to consumers of all ages.36 Although the FTC’s ability to seek monetary relief for harmed 

consumers is now substantially limited following the Supreme Court’s decision in AMG Capital 

Management,

37 the FTC continues to deliver refunds to consumers when possible. These 

payments provide people some recompense for the losses that occurred due to illegal conduct.

In September 2023, the FTC sent a second round of payments in Lifewatch Inc. totaling more 

than $1.04 million to 27,809 people, following a previous round of checks sent in December 

2021 that resulted in $669,195 in refunds to consumers. The FTC and the Florida Attorney 

General alleged that Lifewatch Inc., its officers and related entities bombarded consumers with at 

least a billion unsolicited robocalls pitching supposedly free medical alert systems, and claimed

that the systems were endorsed or recommended by reputable organizations like the American 

Heart Association when they were not. The company’s telemarketers often told consumers that 

they could receive the medical alert system “at no cost whatsoever,” but consumers eventually 

learned that they were responsible for monthly monitoring fees, and it was difficult to cancel 

without paying a penalty. Defendants are permanently banned from telemarketing and prohibited

from misrepresenting the terms associated with the sale of any product or service.

In September 2023, the Claims Administrator in Western Union sent approximately $40 million 

to approximately 25,000 consumers, bringing the total amount returned to consumers to over 

$404 million. The FTC’s settlement was filed in conjunction with a settlement involving the

DOJ, the U.S. Postal Inspection Service, and the U.S. Attorneys Offices for the Middle District 

of Pennsylvania, the Eastern District of Pennsylvania, the Central District of California and the 

Southern District of Florida, where Western Union agreed to pay $586 million and admitted to 

aiding and abetting wire fraud. The FTC alleged that fraudsters around the world used Western 

Union’s money transfer system to perpetrate fraud, such as telemarketing schemes, online scams, 

lottery or prize scams, grandparent scams, and romance scams, even though the company had 

long been aware of these illicit transactions, and that some Western Union agents were complicit 

in the fraud. The FTC complaint alleged that Western Union failed to put in place effective antifraud policies and procedures and failed to act promptly against problem agents. Western Union 

also agreed to implement and maintain a comprehensive anti-fraud program with training for its 

agents and their front-line associates, monitoring to detect and prevent fraud-induced money 

transfers, due diligence on all new and renewing company agents and suspension or termination 

of noncompliant agents.

In February 2023, the Claims Administrator in MoneyGram International sent checks totaling 

more than $115 million to 38,889 people who used MoneyGram to send money to scammers.

The FTC settled charges in November 2018 of allegations that the company failed to take steps 

required under a 2009 FTC order to protect consumers from fraud through its money transfer 

36 The FTC provides updated statistics about where refunds were sent, the dollar amounts refunded, and the number 

of people who benefited from FTC refund programs at www.ftc.gov/refunds.

37 AMG Capital Mgmt., 141 S. Ct. at 1341. See also discussion in Section II(D) below.
FEDERAL TRADE COMMISSION FTC.GOV 1 2

system. In its 2018 filing addressing violations of the 2009 order, the FTC alleged that 

MoneyGram failed to implement the comprehensive fraud prevention program mandated by the 

2009 order, which required the company, among other things, to promptly train, investigate, 

restrict, suspend, and terminate high-fraud agents. The 2009 order also required MoneyGram to 

conduct timely fraud investigations of any agent location that received two or more fraud 

complaints within 30 days, had fraud complaints totaling 5 percent or more of the location’s total 

monthly received transactions, or displayed any unusual or suspicious money transfer activity. 

MoneyGram also was required to terminate locations that may be complicit in fraud-induced 

money transfers. The original FTC case described several scams perpetrated through the 

MoneyGram payment system including lottery or prize scams that often target older adults. 

MoneyGram agreed to a $125 million payment as part of a global settlement, which resolved 

allegations that MoneyGram also violated a separate 2012 deferred prosecution agreement with 

the Department of Justice.38

In March 2023, the FTC began sending payments totaling nearly $2.4 million to consumers who 

paid subscription fees to the stock trading website Ragingbull.com.

39 The FTC’s complaint 

against Raging Bull and its owners, filed in December 2020, alleged that Raging Bull used 

inflated and false earnings claims to induce consumers into signing up for costly and hard-tocancel subscriptions and paying for investment strategies.40 The FTC further alleged that Raging 

Bull and its owners were “bilking consumers out of millions of dollars on a monthly basis” and 

that “a number of these consumers [were] older adults, retirees, and/or immigrants.”

Two months later, the FTC announced that it was sending payments totaling $577,000 to 

consumers who had paid money to GDP Network, a Florida telemarketing company, for 

allegedly selling fraudulent debt relief services.41 According to the complaint filed in July 2020, 

the FTC and the State of Florida alleged that GDP Network and its owners falsely claimed 

affiliations with consumers’ credit card companies and charged consumers upfront fees ranging 

from $995 to $3,995 to reduce their credit card debts. GDP Network targeted older adults and 

financially distressed individuals and obtained sensitive information, such as their passwords, 

social security numbers, and financial information. If consumers sought refunds for GDP 

Network’s supposed debt relief services, the company issued refunds “only when consumers 

38 Press Release, FTC, More than $115 Million in Refunds Sent to Consumers as a Result of FTC, DOJ Charges 

That MoneyGram Failed to Crack Down on Scams (Feb. 10, 2023), available at https://www.ftc.gov/newsevents/news/press-releases/2023/02/more-115-million-refunds-sent-consumers-result-ftc-doj-charges-moneygramfailed-crack-down-scams.

39 Press Release, FTC, FTC Sends Nearly $2.4 Million to Raging Bull Customers After the Company Agrees to Settle 

Charges of Bogus Earnings Claims (March 6, 2023), available at https://www.ftc.gov/news-events/news/pressreleases/2023/03/ftc-sends-nearly-24-million-raging-bull-customers-after-company-agrees-settle-charges-bogusearnings.

40 FTC v. Ragingbull.com et al., No. 1:20-cv-3538 (D. Md. filed Dec. 14, 2020), available at 

https://www.ftc.gov/legal-library/browse/cases-proceedings/2023073-ragingbullcom.

41 Press Release, FTC, FTC Sends More Than $557,000 to Consumers Harmed by Credit Card Interest Rate 

Reduction Scam (May 22, 2023), available at https://www.ftc.gov/news-events/news/press-releases/2023/05/ftcsends-more-557000-consumers-harmed-credit-card-interest-rate-reduction-scam.
FEDERAL TRADE COMMISSION FTC.GOV 1 3

threaten[ed] to contact the Better Business Bureau or a state or federal law enforcement 

agency.”42

In 8 Figure Dream Lifestyle LLC, the FTC alleged that the defendants consistently made false 

or unsubstantiated claims about how much consumers could earn through their programs.43 They 

often said, for example, that a typical person with no prior skills could make $5,000 to $10,000 

in 10 to 14 days. While the defendants marketed their scheme broadly, they also directly targeted 

older consumers. Their marketing to retirees said, “Make sure those golden years are actually 

‘Golden’!!” People who bought the program spent up to $22,000, and rarely earned substantial 

income. In fact, a majority lost money up to their entire investment, and often incurred 

significant loans and credit card debt.44 Defendants agreed to settle with the FTC and 

surrendered funds to the FTC, which the FTC used to pay back consumers.

In October 2021, the FTC sent payments that resulted in $740,000 in refunds. In February 2023, 

the FTC sent a second round of payments totaling more than $390,000 to 1,542 people who 

accepted their first payment and had paid the defendants more than $2,000.

In Triangle Media Corp., the FTC alleged the defendants sold anti-aging and other products, 

including a cognitive enhancement supplement and an anti-aging cream, using deceptively 

advertised free trial offers. Consumers who ordered the free trials were charged for the trial 

shipment, and were also enrolled in a negative-option continuity plan without their consent, 

under which they receive an additional shipment each month and are charged full price for each 

shipment.45 The FTC’s complaint alleges such practices violate the FTC Act, as well as the 

Restore Online Shoppers’ Confidence Act, and the Electronic Fund Transfer Act and its 

implementing Regulation. Defendants agreed to settle the matter. In June 2020, the FTC sent 

checks that resulted in $7.3 million in refunds to consumers. The FTC sent a second round of 

checks in February 2023 totaling $1.3 million.46

42 FTC v. GDP Network, et al., No. 6:20-cv-1192-78DCI (M.D. Fla. July 16, 2020), available at 

https://www.ftc.gov/legal-library/browse/cases-proceedings/192-3137-gdp-network-llc-yf-solution.

43 FTC v. 8 Figure Dream Lifestyle, LLC, No. 8:19-cv-01165 (C.D. Cal. Oct. 4, 2021), available at 

https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3117-8-figure-dream-lifestyle-llc.

44 Press Release, FTC, FTC, Law Enforcement Partners Announce New Crackdown on Illegal Robocalls (June 25, 

2019), available at https://www.ftc.gov/news-events/news/press-releases/2019/06/ftc-law-enforcement-partnersannounce-new-crackdown-illegal-robocalls.

45 FTC v. Triangle Media Corp., No., 18-cv-1388 (S.D. Cal. June 22, 2020), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/172-3108-triangle-media-corporation.

46 Press Release, FTC, Triangle Media Refunds: FTC Returns Money to People Who Were Charged For “RiskFree” Trial Products (Feb. 2023), available at https://www.ftc.gov/enforcement/refunds/triangle-media-refunds.
FEDERAL TRADE COMMISSION FTC.GOV 1 4

In Elite IT Partners, Inc., the FTC alleged that the defendants operated a technical support 

scheme using internet ads targeting consumers looking for email password recovery help.47

According to the FTC’s complaint, the defendants’ representatives falsely told consumers that

their computer problems most likely stemmed from a virus or infection. The telemarketers ran

bogus “diagnostic” tests and used scare tactics and misrepresentations to sell additional service 

plans. The vast majority of consumers that the defendants contacted were older. At the FTC’s 

request, the federal court temporarily shut down the defendants’ scheme and froze their assets.

The defendants agreed to settle this matter. The case was brought as part of a coordinated effort 

with DOJ and other federal and state agencies to take down technical support scams. The FTC 

has returned just over $218,000 to consumers to date.48

In Mile High Madison Group, Inc., the FTC alleged the marketers of three supplements called

Neurocet, Regenify, and Resetigen-D deceptively promoted their products to older Americans 

through direct mail and online using false claims that their products could stop pain and treat 

age-related ailments.49 The defendants claimed their products were anti-aging cure-alls that 

could repair cells and were clinically proven to treat multiple conditions. The FTC alleged the 

defendants also deceptively advertised through fake doctor endorsements and consumer 

testimonials. The defendants agreed to a settlement order barring them from making any claims

about the health benefits of their products unless they are true and supported by scientific 

evidence. The order also imposed a judgment of more than $38.1 million, which is partially

suspended due to an inability to pay after the defendants paid $1.3 million. 

In October 2021, the FTC sent the first set of payments to people who paid $120 or more for 

supplements, which resulted in more than $660,000 in refunds. In December 2022, the FTC sent 

checks totaling just over $368,000 to people who paid between $110 and $119.99 for the 

supplements.

In Seed Consulting, the defendants allegedly partnered with companies, including the defendants 

in two other FTC actions, Nudge and MOBE, to obtain “funding” for people to purchase pricey 

training or coaching programs.50 The FTC charged that the defendants in those two actions 

deceived people, including older adults and retirees, through a variety of misrepresentations 

about their wealth-creation programs. In Seed, the FTC alleged that the defendants engaged in 

“credit card stacking,” which is the practice of charging people thousands of dollars to apply for 

47 FTC v. Elite IT Partners, Inc., No. 2:19-cv-00125 (D. Utah Dec. 10, 2019), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3114-elite-it-partners-inc. 

48 Press Release, FTC, Elite IT Refunds: FTC Sends Checks to People Who Lost Money to a Tech Support Scheme

(Jan. 2023), available at https://www.ftc.gov/enforcement/refunds/elite-it-refunds. 

49 Press Release, FTC, FTC Sends Refunds to Consumers Who Bought Deceptively Marketed Supplements to Treat 

Pain and Age-Related Health Conditions (Oct. 20, 2021), available at https://www.ftc.gov/news-events/news/pressreleases/2021/10/ftc-sends-refunds-consumers-who-bought-deceptively-marketed-supplements-treat-pain-agerelated. 

50 FTC v. Seed Consulting, LLC, No. 2:21-cv-00154 (D. Nev. Jan. 29, 2021), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/182-3183-seed-consulting-llc. 
FEDERAL TRADE COMMISSION FTC.GOV 1 5

personal credit cards on their behalf and inflating people’s income many times over to get high 

credit lines—so that those people could pay for training programs offered by the defendants’ 

partners. In January 2021, the FTC and the Seed defendants reached a settlement that imposes a 

$2.1 million monetary judgment, bars the defendants from charging people to obtain credit cards, 

and bars the defendants from misrepresenting the financial status of anyone to a financial 

institution. In September 2021, the FTC mailed checks that resulted in $1.8 million in refunds to 

consumers.51 In November 2022, the FTC sent a second round of checks totaling more than 

$147,000 to consumers.

In OTA Franchise Corp., the FTC alleged that the defendants used false or unsubstantiated 

earnings claims, often targeted at older consumers, to sell “training programs” costing as much 

as $50,000.52 The FTC also alleged that the defendants misrepresented that the company had a 

patented “strategy” that anyone could use to generate substantial income from trading in the 

financial markets. Evidence obtained by the FTC indicated that many of the defendants’ 

customers did not make any money, and many lost money on top of the money they paid the 

defendants. Evidence obtained by the FTC also indicated that instructors’ claims of amassing 

wealth were false or unsubstantiated. A federal court granted the FTC’s request for a preliminary 

injunction. In September 2020, the defendants agreed to a settlement order that among other 

things prohibits them from making claims about potential earnings unless the claims are truthful 

and they have written documentation to support them. The defendants offered debt forgiveness to 

thousands of consumers who purchased their “training programs,” which resulted in $13.3 

million in debt forgiveness for consumers.

53 In August 2021, the FTC sent checks that resulted in 

an additional $4.6 million in refunds to consumers, and in January 2023, sent a second round of 

checks totaling more than $800,000.

In Neurometrix, Inc., the FTC alleged the defendants deceptively claimed their product, Quell, 

an electrical nerve stimulation device, would treat pain throughout the body when placed below 

the knee.54 The FTC alleged that the defendants lacked scientific evidence to support widespread 

chronic pain relief claims and that their claims about clinical proof and the scope of clearance by 

the U.S. Food and Drug Administration (FDA) were false. The order settling the case bars the 

defendants from making pain-relief claims unless they are true, not misleading, and supported by 

51 Press Release, FTC, FTC Returns $2M to Consumers Who Paid High Upfront Fees to Get “Funding” for 

Expensive, Ineffective Training Programs (Sept. 29, 2021), available at https://www.ftc.gov/newsevents/news/press-releases/2021/09/ftc-returns-2m-consumers-who-paid-high-upfront-fees-get-funding-expensiveineffective-training.

52 FTC v. OTA Franchise Corp., No. 8:20-cv-00287 (C.D. Cal. Sept. 15, 2020), available at 

https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3175-x200032-online-trading-academy.

53 Press Release, FTC, FTC Settlement Requires Online Trading Academy to Forgive Consumer Debt, and 

Principals to Turn Over Millions in Cash and Assets (Sept. 15, 2020), available at https://www.ftc.gov/newsevents/news/press-releases/2020/09/ftc-settlement-requires-online-trading-academy-forgive-consumer-debtprincipals-turn-over-millions.

54 FTC v. Neurometrix, Inc., 1:20-cv-10428 (D. Mass. Sept. 8, 2020), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/172-3130-neurometrix-inc.
FEDERAL TRADE COMMISSION FTC.GOV 1 6

competent and reliable scientific evidence; prohibits misrepresentations about clinical proof or 

the scope of FDA clearance; and requires them to pay redress. The order imposed a $4 million 

judgment and required the defendants to turn over any future foreign licensing payments under 

existing contracts at the time. 

Between September 2020 and August 2021, the FTC sent checks and PayPal payments, which 

resulted in over $3.4 million in refunds. In February 2023, the FTC sent another round of PayPal 

payments totaling over $300,000 to 40,244 people who accepted their first payment.55

3. Criminal Liaison Unit

The FTC’s Criminal Liaison Unit works with federal and state criminal prosecutors to bring 

more consumer fraud cases.

56 Many of these prosecutors have brought criminal cases that built 

on matters the FTC developed in its civil law enforcement actions, or with other forms of 

assistance from the FTC. 

For example, in January 2023, defendant Jennifer Shah was sentenced to 78 months in prison (or 

six and a half years) for a fraudulent telemarketing scheme that victimized older Americans.57

Shah was the last of 23 defendants to plead guilty from the operation, which marketed homebased business opportunities. The FTC provided the U.S. Attorney’s Office for the Southern 

District of New York information from multiple FTC matters to assist the prosecution, which to 

date has resulted in sentences totaling 744 months (or 62 years), including a 60-month sentence 

for former FTC defendant and scheme ringleader Ryan Hult. The FTC provided more than $7 

million in redress for consumers through its civil cases.58

In March 2023, the Cuyahoga County (Ohio) Prosecutor’s Office indicted three individuals and 

one company who used “cryptocurrency ATMs” to defraud millions of victims, many of whom 

55 Press Release, FTC, FTC Refunds Almost $3.9 Million to Purchasers of Deceptively Advertised Quell Wearable 

Pain-Relief Device (Sept. 8, 2020), available at https://www.ftc.gov/news-events/news/press-releases/2020/09/ftcrefunds-almost-39-million-purchasers-deceptively-advertised-quell-wearable-pain-relief-device.

56 Information about the FTC’s Criminal Liaison Unit is available at https://www.ftc.gov/enforcement/criminalliaison-unit. 

57 Press Release, U.S. Department of Justice, Reality Show Cast Member Jennifer Shah Sentenced to 78 Months in 

Prison for Running Nationwide Telemarketing Fraud Scheme (Jan. 6, 2023), available at

https://www.justice.gov/usao-sdny/pr/reality-show-cast-member-jennifer-shah-sentenced-78-months-prisonrunning-nationwide. 

58 Redress Page, FTC, FTC Sends Checks to People Who Paid for Business Coaching Services (Mar. 2023), 

available at https://www.ftc.gov/enforcement/refunds/refunds-business-coaching-services. 
FEDERAL TRADE COMMISSION FTC.GOV 1 7

were elderly.59 The Prosecutor’s Office and the United States Secret Service, which coordinated 

the operation, thanked the FTC for its assistance in the matter.

4. Referrals to the FBI’s Recovery Asset Team

Since 2019, the FTC has referred reports involving high dollar losses to the Federal Bureau of 

Investigation (“FBI”) Internet Crime Complaint Center (IC3) Recovery Asset Team. This team’s 

goal is to “streamline communication with financial institutions and assist FBI field offices with 

the freezing of funds for victims who made transfers to domestic accounts under fraudulent 

pretenses.”60 In 2022, the FBI IC3 Recovery Asset Team responded to 2,838 incidents and with 

the assistance of their banking partners, froze an impressive $433.30 million of the $590.62 

million in reported losses, making recovery possible for many victims.61

The FTC refers reports received through its ReportFraud.ftc.gov website and call center that 

meet certain criteria (typically larger dollar losses) to the FBI IC3 Recovery Asset Team when 

the consumer agrees to the referral. In the past year, the FTC has referred more than 800 reports 

through its Consumer Sentinel Network to the FBI IC3’s Recovery Asset Team. Here are some 

recent success stories involving older adults shared by the FBI IC3 Recovery Asset Team: 

• In January 2023, an older adult reported to the FTC that their business email was 

compromised, resulting in the individual receiving a spoofed email containing fraudulent 

wire transfer instructions to a beneficiary trust account. The individual ultimately sent a 

wire of more than $850,000 to the fraudulent account. The individual quickly reported 

the incident to the FTC, and the FBI IC3 Recovery Asset Team was able to contact the 

recipient bank and freeze almost the full wired amount for possible recovery.

• In March 2023, an older adult reported to the FTC that they placed a call to their 

investment advisor firm because they were unable to access their online account. The call

did not go to their investment advisor, but to a spoofed phone number for Vanguard. The 

individual was told their account had been blocked for inappropriate material and they 

should make an almost $400,000 wire transfer to a fraudulent domestic bank account for 

a cryptocurrency exchange. Since the individual reported the incident quickly to the FTC,

the FBI IC3 Recovery Asset Team was able to contact the recipient bank and freeze the 

full wired amount for possible recovery.

59 Press Release, Cuyahoga County Office of the Prosecutor and U.S. Secret Service, Three Individuals and One 

Business Indicted on Engaging in a Pattern of Corrupt Activity Among Other Charges for Operating 

Cryptocurrency Kiosks in Northeast Ohio (Mar. 2, 2023), available at http://prosecutor.cuyahogacounty.us/enUS/BOA-and-3-people-insicted-cryptocurrency-kiosks.aspx and

https://www.secretservice.gov/newsroom/releases/2023/03/three-individuals-and-one-business-indicted-engagingpattern-corrupt. 

60 Department of Justice Federal Bureau of Investigation, Federal Bureau of Investigation Internet Crime Report 

2022 at 9 (2022), available at https://www.ic3.gov/Media/PDF/AnnualReport/2022_IC3Report.pdf.

61 Id. at 10.
FEDERAL TRADE COMMISSION FTC.GOV 1 8

• In March 2023, an older adult reported to the FTC that they received a pop-up message 

on their frozen computer screen instructing them to call a Microsoft Windows Defenders 

phone number. After placing the call, the individual’s computer was taken over by the 

scammer. The individual was instructed to initiate a wire transfer supposedly to the FTC 

for more than $50,000 to a fraudulent domestic bank account. The individual 

immediately contacted the FTC, and the FBI IC3 Recovery Asset Team was able to 

contact the recipient bank and freeze the full wired amount for possible recovery.

The FTC is proud to partner with the FBI IC3’s Recovery Asset Team to help consumers, 

particularly those experiencing large dollar losses, to recover funds when possible.

D.FTC Efforts to Protect Older Americans Remain 

Handicapped After AMG

In the past fiscal year, the FTC continued its efforts to develop tools to enhance its law 

enforcement efforts. In 2021, the Supreme Court held in AMG Capital Management that the FTC 

did not have authority to seek equitable monetary relief in cases brought under Section 13(b) of 

the FTC Act.62 Prior to this ruling, the FTC had used its Section 13(b) authority to provide

billions of dollars in monetary restitution to consumers affected by unfair or deceptive acts or 

practices, including older adults.

63 This decision constrained the FTC’s ability to obtain redress 

for consumers. The FTC urges Congress to amend Section 13(b) of the FTC Act to revive the 

FTC’s ability to provide refunds to harmed consumers and prevent violators from keeping the 

money they earned by breaking the law. For example, prior to AMG Capital, Office Depot, Inc. 

and a tech support software provider paid $35 million to the FTC to settle allegations that they 

tricked consumers into buying millions of dollars of computer repair and technical services by 

deceptively claiming that their software had found malware symptoms on consumers’ 

computers.64 This type of relief is no longer possible. The FTC continues to strongly support 

legislation to fix AMG. Without it, older Americans will continue to lose money to scammers 

that the FTC cannot return to them.

E. Strategies to Provide Additional Tools Post-AMG to 

Enhance FTC Enforcement Efforts

Consequently, in a response to the AMG decision, the Commission has sought to initiate 

rulemakings to cover a wider category of types of practices, as our statute explicitly permits 

62 AMG Capital Mgmt., 141 S. Ct. at 1341.

63 FTC Act, 15 U.S.C. § 53(b). From FY 2017 to 2021, the Commission returned $11.4 billion to consumers across 

all FTC cases, including those brought solely under the FTC’s Section 13(b) authority.

64 FTC v. Office Depot, Inc. et al., No. 9:19-cv-80431 (S.D. Fl. March 27, 2019), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/172-3023-office-depot-inc.
FEDERAL TRADE COMMISSION FTC.GOV 1 9

consumer redress and/or civil penalties for rule violations.

65 On October 17, 2022, the FTC 

issued a Notice of Proposed Rulemaking addressing impersonation of government and 

businesses (“NPRM”).

66 The proposed rule is aimed at combatting government and business 

impersonation fraud, a pernicious problem that grew worse during the pandemic.67 Government 

impersonators often pretend to represent institutions such as the Social Security Administration,

Medicare/Health and Human Services, IRS, or law enforcement, and may threaten their targets 

with a discontinuation of government benefits, enforcement of tax liability, and even arrest or 

prosecution. Business impersonators may claim there is suspicious activity on a customer’s 

account or offer a refund or prize if the victim will provide some personal information. 

According to FTC data, the most common type of government impersonation fraud involved the 

Social Security Administration,68 with more than 308,000 complaints between 2017 and 2021, 

more than twice the number of the next type.69 As discussed in Section IV below, analysis of 

FTC reports shows older adults reported tremendous losses to impersonation scams: $271

million for business impersonation scams and $186 million for government impersonation scams 

65 15 U.S.C. § 57(b). In addition to the Commission’s rulemaking efforts, the FTC has also revitalized its authority 

to put bad actors on notice that their conduct violates the FTC Act by sending them a Notice of Penalty Offenses. 

These notices outline a number of practices that the Commission has previously found to be unfair or deceptive and 

highlight that engaging in this conduct could lead to civil penalties. See, e.g., Press Release, FTC, FTC Targets 

False Claims by For-Profit Colleges (Oct. 6, 2021), available at https://www.ftc.gov/news-events/news/pressreleases/2021/10/ftc-targets-false-claims-profit-colleges.

66 Trade Regulation Rule on Impersonation of Government and Businesses, 87 Fed Reg. 62741 (Oct. 17, 2022), 

available at https://www.govinfo.gov/content/pkg/FR-2022-10-17/pdf/2022-21289.pdf.

67 Press Release, FTC, FTC Launches Rulemaking to Combat Sharp Spike in Impersonation Fraud (Dec. 16, 2021).

“The COVID-19 pandemic has spurred a sharp spike in impersonation fraud, as scammers capitalize on confusion 

and concerns around shifts in the economy stemming from the pandemic. Incorporating new data from the Social 

Security Administration, reported costs have increased an alarming 85 percent year-over year, with $2 billion in 

total losses between October 2020 and September 2021. Notably, since the pandemic began, COVID-specific scam 

reports have included 12,491 complaints of government impersonation and 8,794 complaints of business 

impersonation.”

68 “The FTC has been warning consumers for years about impersonation scams – calls that falsely claim to come 

from the IRS, the Social Security Administration, or other offices or businesses. The messages try to coerce people 

into making immediate payments or turning over sensitive personal information.” See Press Release, FTC, FTC 

Data Spotlight on Scammers Impersonating Amazon: How Businesses Can Reduce Injury to Consumers (Oct. 20, 

2021), available at https://www.ftc.gov/business-guidance/blog/2021/10/ftc-data-spotlight-scammersimpersonating-amazon-how-businesses-can-reduce-injury-consumers.

69 Trade Regulation Rule on Impersonation of Government and Businesses, 86 Fed. Reg. 72901, 72902 (Dec. 23, 

2021). “From January 1, 2017 through September 30, 2021, consumers reported 1,362,996 instances of government 

impersonation and associated total losses of roughly $922,739,109. The most common such schemes involved Social 

Security Administration (SSA) impersonators, with more than 308,000 complaints alleging SSA impersonation, 

followed by the IRS (124,000) and Health and Human Services/Medicare programs (125,000).” 
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in 2022. The FTC held an informal hearing on the proposed rule on May 4, 2023. This 

rulemaking is ongoing.70 

III. Outreach and Education Activities

A. Pass It On Education Campaign

Pass It On is the FTC’s ongoing fraud prevention education campaign for older adults. 

Campaign materials show respect for the readers’ life experience and accumulated knowledge 

and supply them with resources to read and “pass on” to family and friends to start conversations 

about fraud. The factsheets, bookmarks, videos, presentations, and other materials refresh and 

add to readers’ knowledge by briefly explaining how certain scams work and what a reader can 

do in response. Since the Pass It On campaign began in 2014, the number of topics it covers in 

print and online has expanded, based on community partners’ requests and changes in fraud 

trends. The updated catalog of print and online material addresses these 13 common frauds:

• Business Impersonator Scams

• Charity Fraud

• Government Impersonator Scams

• Grandkid and Family Scams

• Health Insurance Scams

• Home Repair Scams

• Identity Theft

• Investment Scams

• Job and Money-Making Scams

• Romance Scams

• Tech Support Scams

• Unwanted Calls and Text Messages

• “You’ve Won” Scams

The FTC has distributed almost 20 million Pass It On items since the campaign began, including 

more than 2.1 million items in fiscal year 2023. The free English and Spanish print material is 

70 The FTC also continued a number of rulemaking initiatives evaluating existing rules. Of note in the context of this 

report is the Funeral Rule’s Advance Notice of Proposed Rulemaking (“ANPR”), issued on November 2, 2022, 

seeking public comment, among other issues, on whether to require funeral providers to provide online the same 

price disclosures that the Rule mandates when consumers visit a funeral provider in person. Funeral Industry 

Practice Rule, 87 Fed. Reg. 66096, 66097 (Nov. 2, 2022). See, e.g., Press Release, FTC, FTC Seeks to Improve the 

American Public’s Access to Funeral Services Online (Oct. 20, 2022), available at https://www.ftc.gov/newsevents/news/press-releases/2022/10/ftc-seeks-improve-american-publics-access-funeral-service-prices-online. The 

Commission hosted a workshop on September 7, 2023 that further explored the topics raised in the ANPR. Press 

Release, FTC, FTC to Host Workshop Examining Issues Related to Proposed Changes to the Funeral Rule (May 17, 

2023), available at https://www.ftc.gov/news-events/news/press-releases/2023/05/ftc-host-workshop-examiningissues-related-proposed-changes-funeral-rule.
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requested by groups including banks, libraries, police departments, adult protective services

offices, state attorneys general, military support groups, and educational and community groups 

nationwide. Campaign materials are available at www.ftc.gov/PassItOn, www.ftc.gov/Pasalo,

(Spanish), and can be ordered in print at www.ftc.gov/bulkorder.

The FTC routinely emails Consumer Alerts about the topics covered by Pass It On, as well as 

about phishing scams, how to protect your data, and dealing with scammers’ demands for

payment by gift card, wire transfer, and cryptocurrency. The FTC emails the Alerts in English

and Spanish to more than 421,000 subscribers, who include individuals, community groups, 

advocates, national and local news media outlets, and other stakeholders. The FTC also posts 

these Alerts and materials on its consumer website, www.consumer.ftc.gov, so the public can 

read, link to, and share the prevention messages.71

1. Outreach to Older Adults

The FTC collaborates with many organizations across the country to share its consumer 

education messages and inform the public about its work. In this reporting period, FTC staff in 

Washington, DC and eight regional offices have presented, exhibited, or participated in more 

than 600 outreach events with the public, other law enforcement agencies, and stakeholders 

focused on protecting members of a wide range of communities from scams. More than 145 

served older adults and the people who work with them or engaged partner organizations in 

discussion and education about issues that affect older adults. The FTC’s outreach and education 

work also focused on issues related to consumers’ financial resilience and recovery from effects

of the COVID-19 pandemic.

FTC staff participated in events for older adults together with local, state, and federal 

organizations, including the Better Business Bureau (BBB), public libraries, consumer 

organizations, legal services providers, state attorneys general and consumer affairs offices, and

federal agencies including the Internal Revenue Service, Social Security Administration, U.S.

Department of Veterans Affairs, and U.S. Postal Inspection Service. The FTC also joined in 

multiple activities with groups including those described below.

a. AARP members

Staff educated older adults through more than 36 events with AARP members, including 

nationwide and statewide Facebook Live conversations, webinars, and tele-town halls about 

topics including impersonators, identity theft, scams targeting veterans, and romance, charity, and 

post-disaster scams. More than 8,000 AARP members attended a tele-town hall in Ohio where 

they posed questions and got advice from FTC regional staff. In Oregon, more than 350 people 

turned out for the first in-person AARP scam jam since 2019 and learned about identity theft and 

impersonation scams from FTC regional staff.

71 Information about subscribing to Consumer Alerts is available at www.ftc.gov/ConsumerAlerts.
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b. Members of Congress

The FTC joined members of Congress and shared FTC resources at a Town Hall at Bowling 

Green State University’s Elder College in Ohio, a tele-town hall for 4,700 Pennsylvania 

residents, and a Senior Fraud Prevention Seminar attended by 150 people in San Francisco.

c. Military Servicemembers and Veterans

Since the FTC developed the Military Consumer initiative in 2013, the FTC, Department of 

Defense Office of Financial Readiness, and Consumer Financial Protection Bureau’s Office of 

Servicemember Affairs have jointly led the annual celebration of Military Consumer Month. 

Throughout the month, a large network of military partners, including military, federal, and state 

agencies, consumer and military advocates, and trade groups, collaborate to warn veterans and 

servicemembers about the scams that target them. With more than half (56%) of current veterans 

expected to be over age 60 at the end of FY 2023,72 the agency’s military outreach is another 

way of engaging with older adults. This year, some of the FTC’s Military Consumer Month 

activities focused on older veterans. These included joining an AARP Ohio call-in program to 

discuss how veterans can spot and avoid scams, as well as publishing blog posts and social 

media on scams related to the PACT Act, romance scams, investments, and others.73

Agency staff also joined groups including AARP, the U.S. Department of Veterans Affairs, and 

the U.S. Postal Inspection Service in 23 live and virtual presentations to veterans, where they 

discussed scams targeting veterans, identity theft, and how to keep information safe. In 

November 2022, staff talked about scams with veterans at a VA Economic Development 

Initiatives conference.

d. Older Adult Advocates and Allied Professionals

Commission staff distributed Pass It On and other education materials in English and Spanish at 

several conferences related to aging, adult education, library, and older volunteer services. Staff 

attended conferences of the American Society on Aging, whose 5,000 members work in a broad 

range of aging disciplines; AmeriCorps Seniors, a federal program with more than 200,000 

community-based older volunteers nationwide; the TRIAD of Wisconsin, a group of older 

volunteers who coordinate with local law enforcement to reduce crime against older adults; and 

USAging, the national association that supports Area Agencies on Aging.

72 National Center for Veterans Analysis and Statistics, Population Tables: The Nation: Age/Gender: Table 1L, 

available at www.va.gov/vetdata/veteran_population.asp.

73Consumer Alert, FTC, Veterans: You don’t have to pay for help filing for your benefits (Jul. 10, 2023), available 

at https://www.militaryconsumer.gov/blog/veterans-you-dont-have-pay-help-filing-your-benefits; Consumer Alert, 

FTC, Military Consumers and Romance Scams (Jul. 5, 2023), available at

https://www.militaryconsumer.gov/blog/military-consumers-and-romance-scams; Consumer Alert, FTC, Is it a 

legitimate investment opportunity or a scam? (Jul. 20, 2023) available at https://www.militaryconsumer.gov/blog/itlegitimate-investment-opportunity-or-scam.
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The FTC works with libraries to reach communities nationwide, and help libraries and educators

address questions about consumer issues, fraud, and avoiding scams and identity theft. People 

visit libraries and bookmobiles to get information, use technology, and attend programs and 

lectures. More than forty percent of people aged 52-70 visited a library or bookmobile in the last 

twelve months,74 and more than half of people in that age range said libraries help them get 

information to help with decisions.75 Staff attended the Association of Bookmobile and Outreach 

Services, whose members serve patrons in rural and urban locations; Coalition of Adult Basic 

Education, which advances adult education and literacy; Joint Conference of Librarians Of 

Color, which advocates for American Indian, Asian/Pacific American, Black, Chinese and 

Latino libraries and their communities; Teachers of English to Speakers of Other Languages, an 

international association of English language teaching professionals; and the Texas Library 

Association, whose 5,000 members make up the nation’s largest state library association.

In 2021, the FTC launched the Community Advocate Center (CAC) to support legal services 

organizations’ fraud reporting and strengthen the FTC’s connections with historically 

underserved communities.76 Participating legal service providers get a customized link to report 

fraud and other bad business practices directly to the FTC and receive periodic email updates and 

virtual briefings from the FTC. Twelve members of the CAC operate programs dedicated to 

serving older adults. The FTC issued a Consumer Alert about scammers posing as TV and 

internet providers based on reports from CAC member the Center for Elder Law and Justice in 

New York.77

Staff also deepened their connections with front line professionals, older adults, and lower 

income residents of Georgia, Arkansas, and Kansas through virtual state Consumer Protection

Conversations. Each conversation, co-hosted by FTC staff and representatives from local BBB,

legal aid, and state attorney general offices, offered participants information about identity theft, 

current fraud trends in their state, and consumer protection resources to use in their communities.

The FTC’s outreach partnerships with groups and communities throughout the country provide

opportunities to share the agency’s important prevention messages and foster more direct 

communication lines so the FTC learns in real time about ongoing scams and other consumer 

protection problems affecting the public. This, in turn, can generate ideas for policy and 

education initiatives, as well as new case leads.

74 Pew Research Center, Millennials Are the Most Likely Generation of Americans to Use Public Libraries (June 21, 

2017), available at https://www.pewresearch.org/short-reads/2017/06/21/millennials-are-the-most-likely-generationof-americans-to-use-public-libraries/. 

75 Pew Research Center, Most Americans — Especially Millennials — Say Libraries Can Help Them Find 

Trustworthy Information (Aug. 30, 2017), available at https://www.pewresearch.org/short-reads/2017/08/30/mostamericans-especially-millennials-say-libraries-can-help-them-find-reliable-trustworthy-information/. 

76 The Community Advocate Center is available at https://reportfraud.ftc.gov/community.

77 Consumer Alert, FTC, Scammers Are Posing as Your TV and Internet Company (Oct. 19, 2022), available at

https://consumer.ftc.gov/consumer-alerts/2022/10/scammers-are-posing-your-tv-and-internet-company. 
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2. Pandemic Response

The pandemic has had a significant impact on older adults. As the effects of the pandemic have 

evolved, the agency increased its outreach on issues related to financial resiliency. The outreach 

includes posting and sharing advice and resources at www.ftc.gov/MoneyMatters

(www.ftc.gov/AsuntosDeDinero in Spanish) to help people learn — and teach others — how to 

tackle financial issues resulting from or worsened by the pandemic. The website gathers in one 

place dozens of articles, graphics, and ready-made presentations about common money issues,

including finding work, getting loans, and buying or renting a home for consumers and speakers.

Commission staff used a large-scale mailing and presentations to deliver information about 

financial resiliency. In November 2022, staff mailed 13,000 folders with Pass It On fraud 

prevention material to community-based organizations serving older Spanish-speaking adults in 

senior centers, Area Agencies on Aging, and adult education and community centers. Staff 

attended the Qualitas of Life Organization during its Financial Access Fair, called Health, 

Nutrition, and Finance (Salud, Nutrición y Finanzas), and talked with attendees about buying and 

saving money as part of overall consumer financial health. Staff also gave information about 

consumer rights and what to know before you shop. The FTC joined the CFPB, National Center 

on Elder Abuse and SAGE, an advocacy and service organization for older LGBTQ+ people, for 

a webinar focused on financial wellness and introducing participants to the FTC’s Money 

Matters resources. During an AARP California Facebook Live event, FTC staff discussed how to 

avoid scams after a disaster and how to report scams. The event was part of AARP California’s 

Let’s Talk Dinero: Protect Yourself from Fraud series. It was held in English and marketed to 

California’s bilingual Latino community.

IV. Developing Effective Strategies to Protect 

Older Consumers

A.Research and Data Analysis

The FTC collects and analyzes consumer report information through its Consumer Sentinel 

Network (“Sentinel”). Sentinel is a secure online database that provides federal, state, and local 

law enforcement agencies with access to reports from consumers about fraud and other consumer 

problems. Law enforcement agencies and other organizations contribute consumer reports,78 and 

the FTC collects reports directly from the public through its call center and online at

ReportFraud.ftc.gov and ReporteFraude.ftc.gov (Spanish). The Sentinel database is searchable 

by criteria such as the type of fraud or problem and the name, address, and telephone number of 

the reported entity. Using Sentinel, the FTC and its law enforcement partners can analyze reports 

78 Data contributors are listed at https://www.ftc.gov/enforcement/consumer-sentinel-network/data-contributors.
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filed by older adults to look for patterns and trends, identify problematic business practices and 

enforcement targets, and develop cases against targets under investigation.

1. Consumer Sentinel Reports from Older Adults

During calendar year 2022, Sentinel took in more than 5.4 million reports from consumers, both

directly and through its data contributors, about problems they experienced in the market. Over

2.5 million of the reports were about fraud, more than 1.1 million were about identity theft, and 

over 1.7 million were about other consumer problems.79 Consumers reported losing $9 billion to 

fraud in 2022. About 44% of fraud reports filed in 2022 included consumer age information.

About a third (385,590) of reports that included age information came from people 60 and older, 

and their reported losses totaled more than $1.6 billion.

80 Because the vast majority of frauds are 

not reported, these numbers include only a fraction of older adults harmed by fraud.81

These numbers are also not representative of elder financial exploitation. While elder financial 

exploitation is defined as encompassing financial losses caused by both known and unknown 

individuals,82 Sentinel reports are overwhelmingly about fraud perpetrated by strangers that 

occur on a mass scale, such as through robocalls or fake ecommerce websites. These frauds are 

dissimilar to financial exploitation by family members, caretakers and other known individuals.

Recognizing the distinction between financial exploitation perpetrated by known individuals 

rather than by strangers will result in better understanding of the financial harm to older adults

caused by fraud.

79 See generally FTC, FTC Consumer Sentinel Network (last updated July 25, 2023), available at

https://public.tableau.com/profile/federal.trade.commission. Figures are based on reports made directly to the FTC 

and reports provided by all Sentinel data contributors. These figures do not include reports about unwanted calls. 

Sentinel data is self-reported and not a survey. As such, individuals decide whether to file a report and what 

information, if any, to provide. Not all consumers who file a report provide their age, payment method, amount of 

dollar loss, and other data. As referenced in the text above, “other consumer problems” include various categories of 

reports not classified as fraud, such as auto-related reports and reports about cable and satellite TV.

80 Data provided by the Internet Crimes Complaint Center (IC3) are excluded here and throughout this report, except 

where otherwise noted, due to differences in the age ranges collected from consumers.

81 See Anderson, K. B., To Whom Do Victims of Mass-Market Consumer Fraud Complain? at 1 (May 2021), 

available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3852323 (study showed that only 4.8 percent of 

victims of mass-market consumer fraud complained to a Better Business Bureau or a government entity).

82 See, e.g., Weissberger, G.H., et al., Elder Abuse Characteristics Based on Calls to the National Center on Elder 

Abuse Resource Line, at 19 (October 2020), available at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6992470/

(study includes the following definition of elder financial exploitation: Improper, unauthorized, or fraudulent use of 

an older person’s property by a caregiver or trusted individual (abuse) or stranger (victimization) for the benefit of 

someone other than the elderly person.)
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Key findings from the 2022 Sentinel data:

• Older adults (ages 60 and over) were still less likely than younger adults (ages 18-59) to 

report losing money to fraud.

• Older adults continued to report higher individual median dollar losses than younger 

adults. The disparity remained particularly large among people 80 and over compared to 

younger adults.

• Older adults remained much more likely than younger adults to report losing money on 

tech support scams, prize, sweepstakes and lottery scams, and family and friend 

impersonation. 

• Online shopping fraud continued to be the most commonly reported category of fraud in 

which people of all ages indicated they lost money, but older adults remained much less

likely to report losing money to online shopping fraud than younger adults. 

• Losses to investment scams continued to soar, becoming the top fraud type based on 

aggregate reported losses by older adults generally. But for those 80 and over, prize, 

sweepstakes and lottery scams remained the costliest.

• Aggregated reported losses and the number of reports indicating money was lost by older 

adults were highest for online frauds, but reported median individual losses continued to 

be highest for frauds that started with a phone call. 

• Aggregate losses reported by older adults were highest on bank transfers or payments,

followed by cryptocurrency. Credit cards and gift cards were the fraud payment methods 

most frequently reported by older adults.

83

• Analysis points to differences in how older adults in different demographic populations 

may experience fraud. Most notably, older adults most likely to be Asian American and 

Pacific Islander84 reported a much higher share of losses to investment scams, and older 

adults most likely to be Black reported a higher share of losses to prize, sweepstakes and 

lottery scams.

• Working with two different assumptions on the underreporting of fraud, we estimate the 

overall cost of fraud to older adults to be $5.9 billion or $48.4 billion. These figures 

83 The gift card payment method includes cards that hold a specific cash value that can be used for purchases and 

reload cards such as MoneyPak that are used to add value to these cards.

84 See infra note 99 which describes the method used to impute race and ethnicity for this report.
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reflect a considerable degree of uncertainty because the scale of underreporting, 

particularly when losses are high, is not well understood.

These findings, explored more fully below, help inform the FTC’s efforts to protect consumers 

through consumer education, law enforcement, and policy work.

a. Most Older Adults Who Filed Fraud Reports Avoided Losing Any Money

As in previous years, the overwhelming majority of Sentinel fraud reports filed in 2022 by 

people 60 or over did not indicate any monetary loss. Figure 1, which controls for population 

size,85 shows that older adults were 57% more likely to file these no-loss reports about fraud they 

had spotted or encountered—but avoided losing money on—than people ages 18-59.86

Moreover, consistent with previous years, older adults were 18% less likely to report losing 

money to fraud than people ages 18-59. This suggests that older adults may be more likely to 

avoid losing money when exposed to fraud, more inclined to report fraud when no loss has 

occurred, or a combination of these or other factors. The FTC’s most recent fraud survey, 

published in October 2019, also found that what it called the “rate of victimization” for the 

various categories of frauds included in the survey was generally lower for those 65 and older 

than for younger consumers.87

85 The comparison of older adults and younger consumers is normalized against the population size of each age 

group. The analysis is based on U.S. Census Bureau data for population by age. See U.S. Census Bureau, 2017-2021 

American Community Survey 5-Year Estimates.

86 The largest share of 2022 no-loss reports by older adults were about phone scams, and these were most often calls 

from scammers impersonating government agencies and businesses.

87 FTC Bureau of Economics Staff Report, Mass-Market Consumer Fraud in the United States: A 2017 Update at 

76–79 (Oct. 2019), available at https://www.ftc.gov/system/files/documents/reports/mass-market-consumer-fraudunited-states-2017-update/p105502massmarketconsumerfraud2017report.pdf.
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b. Older Adults Reported Higher Median Individual Dollar Losses than 

Younger Consumers

In 2022, as in previous years, younger consumers were more likely to report losing money to 

fraud than older adults, but older adults who did report losing money reported higher median 

individual losses (see Figure 2). People 80 and over reported median individual losses of $1,750, 

far higher than any other age group. The reported median individual dollar loss increased for all 

age groups in 2022 as compared to 2021.
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Some Sentinel reports are filed on behalf of consumers by adult children, spouses, caretakers, or 

others. As in prior years, 2022 Sentinel data show that adults ages 80 and over were more likely 

than other age groups to have a Sentinel report filed on their behalf. Over 16% of reports for 

people 80 and over indicated they were submitted by a person on behalf of the consumer, a far 

higher rate than any other age group.88

c. Some Types of Fraud Affected Older Adults Differently from Younger 

Adults

Figure 3 displays the top fraud categories ranked by the number of reports by older adults 

indicating that money was lost (loss reports). The blue bars show loss reports submitted by older 

adults (age 60 and over), and the gray lines show loss reports filed by younger people (ages 18-

59) for each type of fraud. As shown in Figure 3, controlling for population size, older adults 

were more likely than younger people to report financial losses to certain types of frauds. Three 

categories of fraud continued to stand out in 2022. Older adults were: 1) over six times, or 517%, 

more likely than younger people to report losing money on a tech support scam; 2) more than 

twice as likely to report a loss on a prize, sweepstakes, or lottery scam; and 3) 73% more likely 

to report a loss on a family or friend impersonation scam. Although older adults continued to be 

82 The percentage of reports submitted by another person on behalf of a consumer in 2022 were as follows: 16.3% 

(80 and over), 5.3% (70-79), 3.1% (60-69), 2.5% (50-59), 2.2% (40-49), 1.9% (30-39), 2.2% (20-29), and 3.9% (18-

19). These figures exclude reports collected by Sentinel data contributors because of differences in identifying 

reports submitted by third parties.
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less likely than younger people to report losing money to online shopping fraud, the number of 

loss reports submitted by older adults on this fraud type continued to exceed any other category 

of fraud reported by older adults.

Analysis of total dollars reported lost by older adults by fraud type, shown in Figure 4, highlights 

the tremendous financial harm caused by investment scams, business impersonation scams, and 

romance scams. Reported losses by older adults to investment scams continued to soar, 

increasing from $147 million in 2021 to $404 million in 2022.89 These reports often describe 

fake cryptocurrency investment opportunities that target people through ads, posts, and messages 

89 Here and throughout this section of the report, investment scams refer to fraud reports classified as miscellaneous 

investments and investment advice and stocks and commodity futures trading.
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on social media platforms.90 Losses to business impersonation scams by older adults increased 

78%, with Amazon impersonators once again the most frequently reported.91 Reported losses to 

romance scams by older adults increased 13%, topping the record levels seen in 2021.

92 For 

adults 80 and over, the highest aggregate reported losses were again on prize, sweepstakes and 

lottery scams, with $54 million reported taken in 2022.

90 FTC Consumer Protection Data Spotlight, Reports Show Scammers Cashing in on Crypto Craze (June 3, 2022), 

available at https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2022/06/reports-show-scammerscashing-crypto-craze.

91 Amazon imposters reportedly contact consumers with false claims about compromised accounts or unauthorized 

purchases. See FTC Consumer Protection Data Spotlight, Amazon Tops List of Impersonated Businesses (Oct. 20, 

2021), available at https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2021/10/amazon-tops-listimpersonated-businesses.

92 FTC Consumer Protection Data Spotlight, Romance Scammers’ Favorite Lies Exposed (Feb. 9, 2023), available 

at https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2023/02/romance-scammers-favorite-liesexposed. 
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d. Loss Reports and Aggregate Losses were Highest on Online Fraud, but the 

Highest Median Individual Loss Amounts were to Fraud that Started with a 

Phone Call

In 2022, as shown in Figure 5, older adults filed nearly twice as many loss reports about online 

fraud as phone fraud,93 and their aggregate reported losses to online fraud were also higher. 

However, 2022 reported median individual losses remained far higher for phone fraud at $1,800 

compared to $400 for online fraud. Among the online contact methods, social media continued to

stand out, with total reported losses increasing from $163 million in 2021 to $277 million in 

2022.94 Also notable were text scams, which were second only to phone calls on median 

individual reported losses by older adults. The total loss amount reported by older adults on text 

scams more than doubled from $41 million in 2021 to $90 million in 2022. 

93 Online frauds are defined here as those in which the consumer reported first learning about the fraud on a website 

or app, on social media, or via an online ad or pop-up. Phone frauds are those in which the consumer reported first 

learning about the fraud via a phone call. Text frauds belong to a category separate from phone frauds. 

94 Median individual losses by older adults on scams reported as starting on social media increased from $460 in 

2021 to $800 in 2022.
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The types of frauds older adults most frequently reported losing money to varied by contact 

method. When the contact method was a phone call, older adults most often reported dollar 

losses on business impersonation scams followed by government impersonation scams and prize, 

sweepstakes and lottery scams. When social media was the contact method, older adults most 

often reported losing money to online shopping scams, but their highest aggregate reported 

losses were on investment scams followed by romance scams.95 The largest share of text scam 

reports by older adults were about texts impersonating well-known businesses, particularly 

banks.96

People 80 and over were once again an exception. This age group continued to file loss reports 

about phone fraud at higher rates than online fraud.

97 Their aggregate reported loss to phone 

fraud in 2022 was $86 million, compared to $40 million reported lost to online fraud. About 44% 

of their phone fraud losses were on prize, sweepstakes and lottery scams.

e. Bank Transfers and Cryptocurrency Held the Top Spot for Total Dollars 

Lost, but Credit Cards and Gift Cards Were the Most Frequently Reported 

Payment Methods

People reporting fraud frequently indicate the payment method they used. The first column in 

Figure 6 shows the aggregate dollar losses that older adults reported for the payment methods 

shown. Aggregate losses reported by older adults were highest on bank transfers and payments 

followed by cryptocurrency. While the largest share of reported losses by older adults using both 

these payment methods was on investment scams, reported losses using these methods increased 

across a number of scam types, including scams impersonating businesses and government 

agencies, romance scams, and tech support scams, among others. 

95 In 2022, 49% of aggregate reported losses by older adults to fraud originating on social media were on investment 

scams and 29% were on romance scams.

96 FTC Consumer Protection Data Spotlight, IYKYK: The Top Text Scams of 2022 (June 8, 2023), available at

https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2023/06/iykyk-top-text-scams-2022.

97 In 2022, adults 80 and over filed 3,182 loss reports about fraud that started with a phone call and 2,430 loss 

reports about fraud that started online, with a median reported loss of $3,400 and $700 respectively. 
FEDERAL TRADE COMMISSION FTC.GOV 3 4

The second column in Figure 6 shows that, in 2022, older adults most often reported paying 

scammers with credit cards followed by gift cards. About half their reported credit card 

payments were on online shopping fraud, while their reported gift card payments were 

overwhelmingly on impersonation scams. 

f. Identifying Differences in Fraud and Consumer Issues Affecting Older 

Adults of Color

FTC research and analysis has demonstrated that different demographic communities report 

different types of fraud at different rates.98 This section seeks to identify trends for older adults 

in Black, Latino, and Asian American and Pacific Islander (“AAPI”) populations. Although the 

FTC does not collect race and ethnicity information directly from consumers, a method to impute 

race and ethnicity using name and zip code information has been applied for the purpose of 

98 FTC Staff Report, Serving Communities of Color at 41-46 (Oct. 2021), available at

https://www.ftc.gov/system/files/documents/reports/serving-communities-color-staff-report-federal-tradecommissions-efforts-address-fraud-consumer/ftc-communities-color-report_oct_2021-508-v2.pdf.
FEDERAL TRADE COMMISSION FTC.GOV 3 5

identifying any trends in reporting.99 Using this method, 48,001 fraud reports filed in 2022 from 

older adults most likely to be Black, Latino, and AAPI were identified for analysis.100 The results 

show differences in the reported fraud types and payment methods for each community, as well 

as larger reported losses for older adults most likely to be AAPI.

Figure 7 shows top fraud types by the share of total reported fraud losses by older adults most 

likely to be Black, Latino, and AAPI. The gray bars represent all reports by older adults, 

including reports where no race/ethnicity prediction was made. Each colored bar shows the share 

of total losses from each demographic group from various types of fraud. The data suggest that 

the fraud types with the highest reported dollar losses for older adults as a whole are also among 

the most costly for Black, Latino and AAPI older adults. However, differences are also evident. 

Most notably, 62% of all reported losses by older adults most likely to be AAPI were on 

investment scams, compared to 27% of all reported losses by older adults. The median reported 

loss to investment scams by older adults most likely to be AAPI was a staggering $100,000. 

These reports most often describe fake cryptocurrency investment opportunities. Of reports from 

older adults most likely to be Black, prize, sweepstakes and lottery scams stood out at 16% of the 

total reported losses for this group compared to 9% for older adults generally. The largest share 

of these losses was on scams in which consumers reported that the scammers claimed a 

connection with Publishers Clearing House. Differences were less pronounced for older adults 

most likely to be Latino.

99 The procedure used to impute race and ethnicity for this report combines information from a consumer’s first 

name, surname, and home zip code, with a method known as Bayesian Improved First Name Surname Geocoding 

(BIFSG). Where BIFSG could not be applied, race/ethnicity probabilities were determined using surname and zip 

code (BISG) and using zip code alone where surname could not be used. Race/ethnicity was not predicted for 

reports that did not include a U.S. zip code. Consumers were then classified according to their largest single 

race/ethnicity probability. To check for robustness, statistics were also computed using race probabilities as weights 

and threshold classification methods to ensure that the findings broadly held across methodologies. BISG is a 

standard technique in fair lending analysis for banking supervision, originally explored in Mark N. Elliott et al., 

Using the Census Bureau’s Surname List to Improve Estimates of Race/Ethnicity and Associated Disparities, Health 

Services and Outcomes Research Methodology 9, no. 2. (2009). For more information on BIFSG, see Ioan Voicu, 

Using First Name Information to Improve Race and Ethnicity Classification, Statistics and Public Policy, Volume 5, 

Issue 1 at 1-13 (2018), available at https://www.tandfonline.com/doi/full/10.1080/2330443X.2018.1427012.

100 The number of 2022 reports identified for analysis for each group were as follows: 23,602 Black, 17,112 Latino, 

and 7,287 AAPI. Note that this information only includes a fraction of the older adults in these populations who 

experienced fraud. One study has shown that only about 4.8 percent of the victims of mass-marketing consumer 

fraud complained to the Better Business Bureau or a government agency. Anderson, K. B., To Whom Do Victims of 

Mass-Market Consumer Fraud Complain? at 1 (May 2021), available 

at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3852323 (study showed that only 4.8 percent of victims of 

mass-market consumer fraud complained to a Better Business Bureau or a government entity). Further, research 

involving nine consumer protection matters found that heavily Black and Latino areas complained substantially less 

relative to their rate of victimization after controlling for other demographic characteristics. See Raval, D., Whose 

Voice Do We Hear in the Marketplace?: Evidence from Consumer Complaining Behavior, Marketing Science 

(2020), 39 (1), 168-87, available at http://deveshraval.github.io/complaintBehavior.pdf.
FEDERAL TRADE COMMISSION FTC.GOV 3 6

Figure 8 shows the differences in the top fraud contact methods reported by older adults for each 

demographic group by the share of total reported fraud losses. Phone fraud accounted for a larger 

share of the fraud losses reported by older adults most likely to be Black. The largest share of 

these losses were to scams impersonating Publishers Clearing House. A much larger share of 

aggregate losses by older adults most likely to be AAPI were to scams that started with an ad, 
FEDERAL TRADE COMMISSION FTC.GOV 3 7

post or contact on social media. These reported losses were overwhelmingly on investment 

scams.101

Figure 9 shows the differences in the top fraud payment methods reported by older adults for 

each of the three demographic groups. A larger share of aggregate losses and loss reports by 

older adults most likely to be AAPI were to scams that took money by bank transfer or payment 

and cryptocurrency. The largest share of these losses was on investment scams. About one in 

four loss reports by older adults most likely to be Black and Latino indicated gift card as the 

payment method. These losses were most often on scams impersonating businesses and 

government agencies.

101 In 2022, older adults most likely to be AAPI reported losing $46 million to fraud that started with an ad or 

contact on social media. About $37 million of these losses were on investment scams.
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Fraud reports from older adults in each demographic group also show differences in individual 

loss amounts and the share of reports that indicated any money was lost. The median reported 

loss in 2022 was $750 for the older adults most likely to be Black, $959 for older adults most 

likely to be Latino, and $2,500 for older adults most likely to be AAPI, compared to $850 for all 

older adults. Aggregate reported losses were also highest for older adults most likely to be AAPI 

at $138 million compared to $78 million and $72 million for older adults most likely to be Black 

and Latino, respectively. As with older adults generally, most fraud reports from the three 

demographic groups were no-loss reports.102

102 In 2022, 24% of fraud reports by all older adults indicated a monetary loss. The share of fraud reports indicating 

a monetary loss for each demographic group was as follows: 27% (Black), 26% (Latino), and 29% (AAPI). 
FEDERAL TRADE COMMISSION FTC.GOV 3 9

g. Estimating the Overall Cost of Fraud to Older Adults

While Sentinel provides invaluable information about the nature of fraud, as well as broad trends 

in fraud, estimating the cost of fraud to older adults is challenging when the data available is 

limited. What’s reported to Sentinel and its contributors is far less than the fraud people actually 

experience. This underreporting results in an incomplete picture of the scale of the problem. For 

example, while many people don't report fraud at all, others might report it to an authority that 

doesn't share reports with Sentinel. Or they might report it to an authority that shares with 

Sentinel only some of the data they collect. 103 Furthermore, some populations may have lower 

reporting rates than others, and some frauds may be less likely to be reported than others. 

Finally, people who lose large amounts of money might be more likely to report the fraud than 

people who lose less.

What is clear is that the scale of the underreporting problem is uncertain. An FTC study of mass 

market fraud analyzed several FTC surveys and found that just 2.6% of consumers who 

experience fraud said that they reported the incident to a government agency. However, the 

frauds covered in these surveys generally resulted in low loss amounts.104

One novel study took a more direct approach, matching FTC enforcement data in nine cases to 

consumer reports about the same companies. 105 Affected consumers named in case records were 

compared to consumer reports to determine whether each consumer had reported their 

experience to the FTC or other data contributors. These results show an average 2.0% reporting 

rate in the cases with average losses of less than $1,000 and a 6.7% reporting rate in cases with 

an average loss of over $1,000. None of the cases in the study had an average loss of $10,000 or 

more.

To extrapolate the missing losses and better estimate the cost of fraud – albeit with a 

considerable degree of uncertainty – we take two approaches using these estimated reporting 

rates. First, we assume that Sentinel includes just 2.0% of all losses from consumers who lost 

under $1,000, and 6.7% of all losses from consumers who lost $1,000 or more. Given these 

103 Most notably, Sentinel contains only a subset of the fraud reports collected by BBB and IC3, and 2022 BBB 

reports do not generally include a dollar loss figure.

104 See Anderson, K. B., To Whom Do Victims of Mass-Market Consumer Fraud Complain? at 1 (May 

2021), available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3852323. This study found that just 4.8% of 

consumers who experienced a fraud reported the incident to BBB or a government agency, and 2.6% to a 

government agency. This estimate was based on consumer self-reports. In “Mass Market Consumer Fraud in the 

U.S.: A 2017 Update,” Anderson found the median loss of fraud victims reporting a dollar loss amount was $100, 

and the 75th percentile loss was $250. See https://www.ftc.gov/system/files/documents/reports/mass-marketconsumer-fraud-united-states-2017-update/p105502massmarketconsumerfraud2017report.pdf.

105 See Raval, D., Whose Voice Do We Hear in the Marketplace?: Evidence from Consumer Complaining Behavior,

Marketing Science (2020), 39 (1), 168-87, available at http://deveshraval.github.io/complaintBehavior.pdf.
FEDERAL TRADE COMMISSION FTC.GOV 4 0

assumptions, the estimated 2022 overall loss, adjusted to account for underreporting, would be 

$137.4 billion,106 with an estimated $48.4 billion loss by older adults.107

Since high dollar losses account for the lion’s share of all losses reported to Sentinel and its 

contributors, the first approach might overestimate unreported fraud losses.

108 A second, more 

conservative approach assumes that reporting rates are higher still for much more costly frauds. 

If we assume that 100% of people who experienced losses of $10,000 or more reported, and are 

therefore included in Sentinel, we would obtain a very conservative estimate of $20.5 billion in 

overall fraud losses, with $5.9 billion lost by older adults.109

2. Hearing Directly from Older Adults About FTC Impersonators

The FTC has continued to receive reports about scammers pretending to work at or be affiliated 

with the FTC.110 These scammers tell a variety of lies to convince people to buy gift cards and 

share the codes, send cash or gold bars, buy cryptocurrency, transfer money, or share bank 

account information. Recently, scammers have been telling people that their money, including 

their retirement accounts, have been compromised, or are at risk of being frozen, and they should 

106 The 2022 reported fraud loss figures used for this purpose are $98.6 million (combined reported losses under 

$1,000) and $8.9 billion (combined losses of $1,000 or more). This includes the subset of IC3 data that is 

contributed to Sentinel. 

107 About 84% of the reported losses used in this analysis included age data, and 35.5% of these losses were reported 

by adults 60 and older. We assumed that age data was “missing at random” conditional on loss amount; that is, that 

consumers who did not report age had the same age distribution as consumer who did report age for a given loss 

bracket. This assumption may be conservative. For example, Grosz and Raval, “Hassle Costs and Consumer Voice: 

Evidence from a Website Redesign” (2023) examine a change to the FTC’s reporting website that improved 

usability. Grosz and Raval, “Hassle Costs and Consumer Voice: Evidence from a Website Redesign (2023) 

available at https://deveshraval.github.io/websiteRedesign.pdf. Grosz and Raval find that the change both 

substantially increased consumer reports and reduced the share of consumers not reporting age, and the share of 

older adults who filed a report increased the most. This could reflect either increased reports from older adults or 

that older adults were more likely not to report age than other groups.

108 While just 15% of people who reported a fraud loss in 2022 lost $10,000 or more, their combined losses were 

equal to 93% of all 2022 losses reported to Sentinel. 

109 The 2022 reported fraud loss figures used for this purpose are $98.6 million (combined reported losses under 

$1,000) and $556.6 million (combined reported losses between $1,000 and $10,000), and $8.3 billion (combined 

reported losses of $10,000 or more). This includes the subset of IC3 data that is contributed to Sentinel. Losses 

reported by older adults made up 20.6% of losses under $1,000, 25.3% of losses between $1,000 and $10,000, and 

36.3% of losses above $10,000.

110 FTC impersonators are one of the top 5 types of government impersonator reports. See FTC, Explore 

Government Imposter Scams (last updated July 25, 2023), available at

https://public.tableau.com/app/profile/federal.trade.commission/viz/GovernmentImposter/Infographic; Consumer 

Alert, FTC, The FTC Won’t Demand Money, Threaten You, or Promise You a Prize (July 5, 2023), available at

https://consumer.ftc.gov/consumer-alerts/2023/07/ftc-wont-demand-money-threaten-you-or-promise-you-prize; 

Consumer Alert, FTC, Will the FTC Call or Write You? Will They Demand Money? (Feb. 13, 2023), available at

https://consumer.ftc.gov/consumer-alerts/2023/02/will-ftc-call-or-write-you-will-they-demand-money.
FEDERAL TRADE COMMISSION FTC.GOV 4 1

move all of the funds to “protect” them. Losses from these scams can be devastating, particularly 

for those losing retirement savings late in life.

The FTC has continued its program engaging with older adults who reported losing money to 

FTC impersonators. These adults often talk about how these scammers tell convincing stories 

that appear legitimate. The fact that the caller says they are with the FTC makes them a trusted 

voice. These adults also describe how the scammers called daily to build a rapport, lowering any 

suspicions as they requested more payments.

After listening to these stories, FTC staff has found it important to make sure these older adults 

know that the experiences were scams and the FTC will never demand money or personal 

information. Because these scammers are so good at what they do, it can be challenging to help 

people believe that FTC staff are legitimate and that the truth is that the previous callers were 

scammers. Taking the time to reach out to these consumers has been an important way for the 

FTC to hear more about these terrible scams, while empowering these older adults with 

information to identify and avoid such scams in the future. 

B.Coordinated Efforts to Protect Older Consumers

The FTC’s Every Community Initiative leads the agency’s strategic planning for the protection 

of older consumers. As highlighted in the 2021 Serving Communities of Color Report, different 

types of consumer protection issues affect different groups of people, and this Initiative examines 

the impact of various schemes on distinct groups, including older adults, military service 

members and veterans, Black Americans, Latinos, Asian Americans, Native Americans, 

communities who speak languages other than English, and other groups.111 The Initiative relies 

on research and input from numerous resources to develop strategies to prevent fraud, inform the 

agency’s law enforcement program, and expand outreach, including from the FTC’s Senior 

Fraud Advisory Office, which the FTC created pursuant to the Seniors Fraud Prevention Act of 

2022,112 and stakeholders in communities. These partnerships across the country have been 

extremely valuable in the FTC’s approach to protecting older adults in a wide range of 

communities from financial loss.

111 FTC Staff Report, Serving Communities of Color: A Staff Report on the Federal Trade Commission’s Efforts to 

Address Fraud and Consumer Issues Affecting Communities of Color (Oct. 2021), available at

https://www.ftc.gov/system/files/documents/reports/serving-communities-color-staff-report-federal-tradecommissions-efforts-address-fraud-consumer/ftc-communities-color-report_oct_2021-508-v2.pdf.

112 The FTC’s Senior Fraud Advisory Office advises the Commission on fraud prevention strategies, monitors the 

market for emerging fraud trends impacting older adults, and coordinates with our law enforcement partners to 

disseminate consumer education regarding these new trends. See Fraud and Scam Reduction Act, Section 101, 

Division Q of the Consolidated Appropriations Act, 2022, Pub. L. No. 117-103, available at 

https://www.congress.gov/117/plaws/publ103/PLAW-117publ103.pdf. Subtitle B of the Act, referred to as the 

“Seniors Fraud Prevention Act of 2022,” requires the FTC to establish an Advisory Office to, among other 

responsibilities, advise the Commission on the prevention of fraud targeting seniors, monitor the market for fraud 

trends impacting older adults, and disseminate consumer education about those trends in coordination with the U.S. 

Department of Health and Human Services; U.S. Department of Justice; U.S. Postal Inspection Service; and U.S. 

Postal Service.
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For example, to pursue law enforcement actions that have the largest possible impact, the FTC 

coordinates with federal, state, local, and international agencies, including those with criminal 

authority. Through partnerships, the FTC leverages resources to track down fraudsters and build 

cases to stop them. In particular, the FTC participates in the Global Anti-fraud Enforcement 

Network, a multilateral network of agencies that enforce laws prohibiting mass marketing fraud. 

The Network has been pivotal in enforcement actions against entities that have defrauded 

millions of older consumers.

The FTC has also continued to be an active member of the Elder Justice Coordinating Council, a 

multi-agency federal entity that coordinates activities across the federal government related to 

elder abuse, neglect, and exploitation. Led by the Assistant Secretary for Aging within the 

Department of Health and Human Services (“HHS”), the EJCC meets twice a year with the goal 

of better coordinating the federal response to elder abuse.

113 The EJCC and its staff-level 

working group have strengthened the FTC’s connections with other federal government offices 

that are also working to combat elder abuse and has facilitated valuable information sharing and 

coordination.

C.Scams Against Older Adults Advisory Group

In addition to working with partners through the Every Community Initiative and the EJCC, the 

FTC also coordinates efforts with a wide variety of stakeholders through an Advisory Group it 

established pursuant to the Stop Senior Scams Act.114 The Scams Against Older Adults Advisory 

Group is comprised of twenty-one representatives from government, industry, and consumer 

advocacy groups.115 It held its first public meeting on September 29, 2022116 where it launched 

113 HHS convened the Elder Justice Coordinating Council in accordance with the Elder Justice Act passed in 2010. 

The Council consists of heads of federal departments and other government entities, including the FTC, identified as 

having responsibilities, or administering programs, relating to elder abuse, neglect, and exploitation. See HHS, What 

is the Elder Justice Coordinating Council? (last modified Nov. 1, 2022), available at

https://www.acl.gov/programs/elder-justice/elder-justice-coordinating-council-ejcc.

114 Congress enacted the Fraud and Scam Reduction Act, Section 101, Division Q of the Consolidated 

Appropriations Act, 2022, Pub. L. No. 117-103 on March 15, 2022. See

https://www.congress.gov/117/plaws/publ103/PLAW-117publ103.pdf. Subtitle A of the Act, referred to as the “Stop 

Senior Scams Act,” requires the FTC to create an Advisory Group comprised of various members, including those 

identified in the Act.

115 The Advisory Group is comprised of representatives of the following entities: AARP; AmeriCorps Senior; 

Chamber of Digital Commerce; Commodity Futures Trading Commission; Consumer Financial Protection Bureau; 

Federal Deposit Insurance Corporation; Federal Reserve Board; Federal Trade Commission; Financial Crimes 

Enforcement Network; Financial Industry Regulatory Authority; Innovative Payments Association; National Retail 

Federation; Office of the Attorney General for the State of Vermont; Retail Gift Card Association; Securities and 

Exchange Commission; The Money Services Round Table; U.S. Department of Health and Human Services; U.S. 

Department of Justice; U.S. Department of Treasury; U.S. Postal Inspection Service; and USTelecom.

116 Press Release, FTC, FTC to Convene First Meeting of Scams Against Older Adults Advisory Group on Sept. 29 

(Sept. 12, 2022), available at https://www.ftc.gov/news-events/news/press-releases/2022/09/ftc-convene-firstmeeting-scams-against-older-adults-advisory-group-sept-29; see also FTC, Scams Against Older Adults Advisory 
FEDERAL TRADE COMMISSION FTC.GOV 4 3

four initiatives to address fraud impacting older adults. These initiatives are focused on: 

1) expanding consumer education efforts; 2) improving industry training on scam prevention; 3) 

identifying innovative or high-tech methods to detect and stop scams; and 4) developing research 

on consumer or employee engagement to reduce fraud. To tackle these initiatives, the Advisory 

Group formed four committees led by the FTC and one or more Advisory Group members, and 

invited interested members of the public with relevant expertise to submit applications to join a 

committee. The FTC and the committee co-leads also identified key stakeholders and extended 

invitations to those partners to assist the Advisory Group’s work. As a result of broad public 

interest and the Advisory Group’s recruiting efforts, the four committees include a diverse array 

of collaborators with expertise from academia; local, state and federal government; trade 

associations, businesses, and other industry members; and consumer advocacy and other nonprofit organizations, which are all joining forces to help stop scams from impacting older 

adults.117 The committees began meeting regularly in December 2022, and are focused as 

follows: 

Consumer Education Committee. The Consumer Education Committee is led by AmeriCorps, 

Cuyahoga County Consumer Affairs, FTC, and the U.S. Department of Treasury. The 

committee’s work is divided into two parts: the Outreach Subcommittee and the Guiding 

Principles Subcommittee. The Outreach Subcommittee is working to identify more effective 

ways to reach older adults. To help older adults protect themselves from scams, subcommittee 

members are implementing test pilot projects that involve sharing consumer education materials 

with an expanded network of trusted community members. Members of this subcommittee are 

using the pilot projects to experiment with new materials, partnerships, or other communication 

channels to see if they result in better outcomes than their traditional outreach methods. For 

example, the FTC’s own pilot, the Fraud Fighters outreach program, builds on the Pass It On

campaign, offering train-the-trainer sessions to a range of participants to determine if it enhances 

the experience and results for participants and their respective audiences. The subcommittee 

meets monthly to discuss important topics and assist members design or implement their pilot 

projects, including the importance of word choice and plain language in messaging, the needs 

and challenges of offering and delivering in-language resources, and the benefits of building 

partnerships. 

The Guiding Principles Subcommittee is working to glean principles to help people and 

organizations of all types more effectively reach older adults on scam-related topics. They are 

doing this by drawing on members’ own experiences from prior outreach efforts. Subcommittee 

members derive their expertise from varied backgrounds including local, state, and federal 

government, industry, and non-profit organizations. Members meet monthly to share their 

Group Meeting (Sept. 2022), available at https://www.ftc.gov/news-events/events/2022/09/scams-against-olderadults-advisory-group-meeting.

117 Press Release, FTC, FTC Announces Members of the Stop Senior Scams Act Advisory Committees Aimed at 

Protecting Older Adults Against Scams (Dec. 7, 2022) available at https://www.ftc.gov/news-events/news/pressreleases/2022/12/ftc-announces-members-stop-senior-scams-act-advisory-committees-aimed-protecting-older-adults

(last visited July 5, 2023); see also FTC, Scams Against Older Adults Committee Members (last visited Sept. 2023), 

available at https://www.ftc.gov/system/files/ftc_gov/pdf/sssa-committee-list.pdf.
FEDERAL TRADE COMMISSION FTC.GOV 4 4

outreach experiences, including materials used, research conducted or relied on, and any 

measured outcomes from their past outreach campaigns. The two subcommittees will distill their 

discussions and learnings into a document outlining guiding principles and best practices that 

many different organizations can utilize to enhance their fraud prevention communications with 

older adults.

Industry Training Committee. The Industry Training Committee is led by AARP and the FTC. 

The committee’s work is focused on implementing the Stop Senior Scams Act’s mandates by 

collecting information on employee training and educational materials used by industry and 

discussing how they can be used as a guide to educate employees on identifying and preventing

scams that affect older adults. Committee members come from a wide range of industries

including financial institutions, digital assets, gift cards, wire transfers, retail, and other payment 

companies. Committee members also include consumer advocates, trade associations, and state 

and federal government. The committee has identified several principles of effective employee 

training and is meeting regularly to discuss each principle in greater depth. In its meetings, 

committee members volunteer to explain how their organization approaches a particular 

principle and share examples of their training materials that illustrate their approach. The 

committee will produce, among other outputs, a guidance document describing the principles of 

effective employee training that can be applied and adapted to any industry segment. 

Technology and New Methods Committee. The Technology and New Methods Committee is led 

by the Consumer Financial Protection Bureau, FTC, U.S. Department of Justice, and 

USTelecom. The committee’s work is concentrated on identifying technologies that can help 

stakeholders spot scams and promoting other ways that stakeholders can collaborate to provide 

greater protection to older adults from the impact of fraud. For example, this collaboration could 

include sharing data and information more broadly to make fraud detection easier. Since 

December 2022, the committee meets monthly and has focused on sharing information regarding 

the strategies and techniques committee members currently use to detect and stop scams. 

Committee members come from a diverse range of industries, and sharing information on their 

different approaches to mitigate fraud has been educational for the members. The committee has 

also invited guest speakers to present to the members on different models of effective industry 

collaboration. The committee will collate a list of possible collaborations that can help provide 

older adults additional protection from the impacts of fraud, and committee members will 

commit to working on one or more of these projects.

Scam Prevention Research Committee. The Scam Prevention Research Committee is led by the 

Consumer Financial Protection Bureau, FTC, Financial Industry Regulatory Authority, 

International Association of Better Business Bureaus, and the U.S. Department of Justice. The 

committee draws expertise from fraud prevention experts from non-profits, government, 

industry, as well as several researchers who have authored studies relevant to the Commission’s 

work. The committee has completed an initial survey of the relevant research, with a focus on 

research addressing fraud prevention messaging. The committee is synthesizing the information 

they have reviewed. The committee plans to identify key takeaways that can serve as a resource 

for the Consumer Education Committee as it prepares information to assist those who prepare 

consumer messaging or education on scam prevention on how they can integrate research-based 

recommendations into existing scam prevention methods. The Scam Prevention Research 

Committee also plans to prepare a resource that will highlight research gaps and propose 
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questions that warrant further exploration to encourage additional research on these topics. This 

document can serve as a reference for both researchers developing proposals and for agencies 

and organizations that are interested in funding research on scam prevention.

V. Conclusion

The FTC is committed to protecting older adults through aggressive law enforcement, continuing 

research efforts, and effective outreach and education. It will persist in using all these tools, 

while also coordinating with a wide range of stakeholders, as it works to protect older adults in 

the future.
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Appendix A – Federal Trade Commission FY 2023

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Passport 

Automotive 

Group, Inc., et 

al.

8:22-cv02670District of 

Maryland

10/18/2022 Equal Credit 

Opportunity Act 

(ECOA)

Alleged the defendants 

participated in deceptive and 

unfair acts or practices in the 

advertising, sales, and financing 

of motor vehicles.

Settlement

In the Matter of 

Drizly, LLC

FTC Matter 

No. 2023185

FTC 

Administrative 

Matter

10/24/2022 Data 

Privacy/Securit

y

Alleged that security failures by 

the defendants, including the 

company and CEO, led to a data 

breach exposing the personal 

information of about 2.5 million 

consumers.

Consent 

Order

In the Matter of 

Chegg, Inc.

FTC Matter 

No. 2023151

FTC 

Administrative 

Matter

10/31/2022 Data 

Privacy/Securit

y

Alleged the defendant's lax data 

security practices exposed 

sensitive information about 

millions of its customers and 

employees.

Consent 

Order

Federal Trade 

Commission, 

The People of 

the State of 

California v. 

Ygrene Energy 

Fund Inc.

2:22-CV07864Central 

District of 

California

10/28/2022 Mortgage Acts 

and Practices 

Advertising 

Rule

Alleged defendant deceived 

consumers about the potential 

financial impact of its financing 

and unfairly recorded liens on 

consumers’ homes without their 

consent.

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 4 7

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Vonage 

Holdings Corp., 

et al.

3:22-cv-6435 District of 

New Jersey

11/3/2022 Restore Online 

Shoppers’ 

Confidence Act 

(ROSCA)

Alleged the defendants unfairly 

charged consumers without their 

express informed consent and 

failed to provide simple 

mechanisms to cancel their 

service.

Settlement

Federal Trade 

Commission v. 

ACRO Services 

LLC, et al.

3:22-cv00895Middle District 

of Tennessee

11/7/2022 Telemarketing 

Sales Rule

(TSR)/Credit 

Repair

Alleged the defendants violated 

the TSR by using telemarketers to 

call consumers and pitch their 

deceptive credit card debt relief 

scheme.

Default 

Judgment

Federal Trade 

Commission v. 

DK Automation 

LLC, et al.

1:22-cv23760Southern 

District of 

Florida

11/16/2022 Business 

Opportunity 

Rule/Consumer 

Review 

Fairness Act 

(CRFA)

Alleged the defendants made 

false or unsubstantiated earnings 

claims, violated the Business 

Opportunity Rule by making 

false claims and failing to provide 

required disclosures, and violated 

prior Commission decisions 

regarding money-making claims 

and endorsements.

Settlement

Federal Trade 

Commission v. 

Precision 

Patient 

Outcomes, Inc., 

et al.

4:22-cv07307Northern 

District of 

California 

11/18/2022 COVID-19 

Consumer 

Protection Act 

(CCPA)

Alleged the defendants 

deceptively advertised that their 

dietary supplement

"COVID/VIRUS Resist" treats, 

prevents, or mitigates COVID-19.

Litigation 

Ongoing
FEDERAL TRADE COMMISSION FTC.GOV 4 8

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

United States of 

America, State 

of Wisconsin v. 

Consumer Law 

Protection 

LLC., et al. 

(Square One)

4:22-cv01243Eastern 

District of 

Missouri

11/21/2022 FTC's Cooling 

Off Rule 

Alleged the defendants scammed 

consumers—mostly older 

adults—out of more than $90 

million in a massive timeshare 

exit scam.

Litigation 

Ongoing

In the Matter of 

Google LLC 

and 

iHeartMedia, 

Inc.

FTC Matter 

No. 2023092

FTC 

Administrative 

Matter

11/28/2022 False 

Endorsement 

Claims

Alleged the defendants had on-air 

talent make false endorsement 

claims for the Google Pixel 4 

phone.

Consent 

Order

United States of 

America v. Epic 

Games, Inc.

5:22-CV00518Eastern 

District of 

North Carolina 

12/19/2022 Children’s 

Online Privacy

Protection Rule 

(COPPA) and 

use of unfair 

design

Alleged the defendants violated 

the Children’s Online Privacy 

Protection Act (COPPA) and 

used unfair default settings that 

exposed users to harm.

Settlement

In the Matter of 

Epic Games, 

Inc.

FTC Matter 

No. 1923203

FTC 

Administrative 

Matter

12/19/2022 Unfair Billing 

Practices and 

Unfair Denial of 

Account Access

Alleged the defendants used dark 

patterns and other deceptive 

practices to trick players into 

making unwanted purchases and 

let children rack up unauthorized 

charges without any parental 

involvement.

Consent 

Order
FEDERAL TRADE COMMISSION FTC.GOV 4 9

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

United States of 

America v. 

Eliza Johnson 

Bacot 

1:23-cv00058Northern 

District of 

Georgia

1/5/2023 COVID-19 

Consumer 

Protection Act 

Alleged the defendant made 

numerous claims about the ability 

of various doTERRA products to 

prevent, treat, or cure COVID-19.

Settlement

United States of 

America v. Dr. 

Tina Wong

2:23-cv00063Central 

District of 

California

1/5/2023 COVID-19 

Consumer 

Protection Act 

Alleged the defendant made 

numerous claims about the ability 

of various doTERRA products to 

prevent, treat, or cure COVID-19.

Settlement

United States of 

America v. 

Lauren Busch

2:23-cv00009District of 

Utah

1/5/2023 COVID-19 

Consumer 

Protection Act 

Alleged the defendant made 

numerous claims about the ability 

of various doTERRA products to 

prevent, treat, or cure COVID-19.

Settlement

Federal Trade 

Commission v. 

Wealthpress 

Holdings LLC, 

et al.

3:23-cv-46 Middle District 

of Florida

1/12/2023 Restore Online 

Shoppers’ 

Confidence Act 

and Notice of 

Penalty 

Offenses

Alleged the defendants used 

deceptive and unsubstantiated 

earnings claims to sell consumers 

investment advising services.

Settlement

In the Matter of 

Instant Brands 

LLC

FTC Matter 

No. 2223140

FTC 

Administrative 

Matter

1/18/2023 Made In USA 

(MUSA)

Alleged the defendant made false 

claims that all of its popular glass 

measuring cups were made in the 

United States during a time when 

some measuring cups were 

imported from China.

Consent 

Order
FEDERAL TRADE COMMISSION FTC.GOV 5 0

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

LCA-Vision 

(LasikPlus)

FTC Matter 

No. 1923157

FTC 

Administrative 

Matter

1/19/2023 Deceptive 

Advertising

Alleged the defendant used 

deceptive bait-and-switch 

advertising to mislead consumers 

into believing they could have 

their vision corrected for less than 

$300.

Consent 

Order

United States of 

America v. 

GoodRx

Holdings, Inc.

3:23-cv-460 Northern 

District of 

California

2/1/2023 Health Breach 

Notification 

Rule (HBNR)

Alleged the defendant committed 

deceptive and unfair practices by 

sharing consumers’ personal 

health information with 

Facebook, Google, and other 

companies, and violated the 

Health Breach Notification Rule 

by failing to notify consumers of 

those unauthorized data 

disclosures.

Settlement

In the Matter of 

The Bountiful 

Company

FTC Matter 

No. 2223019

FTC 

Administrative 

Matter

2/16/2023 Review 

Hijacking

Alleged the defendant deceived 

consumers into thinking that its 

newly introduced supplements 

had more product ratings and 

reviews, higher average ratings, 

and “#1 Best Seller” and 

“Amazon’s Choice” badges.

Consent 

Order
FEDERAL TRADE COMMISSION FTC.GOV 5 1

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

United States of 

America v. 

Stratics 

Networks, Inc., 

et al.

3:23-cv00313Southern 

District of 

California

2/16/2023 Telemarketing 

Sales Rule 

Alleged the defendants 

transmitted millions of illegal 

VoIP and ringless voicemail 

robocalls pitching phony debt 

relief services.

Partial 

Settlement, 

Litigation 

Ongoing 

In the Matter of 

BetterHelp, Inc.

FTC Matter 

No. 2023169

FTC 

Administrative 

Matter

3/2/2023 Data 

Privacy/Securit

y

Alleged the defendant revealed 

consumers’ sensitive data with 

third parties such as Facebook 

and Snapchat for advertising after 

promising to keep such data 

private.

Consent 

Order

United States of 

America v. 

Dalal A. 

Akoury, et al. 

(AWAREmed) 

2:23-cv00026Eastern 

District of 

Tennessee

3/16/2023 Opioid 

Addiction 

Recovery Fraud 

Prevention Act 

(OARFPA)

Alleged the defendants made 

false or unsupported claims for 

addiction treatment services, 

cancer treatment services, and the 

treatment of other serious 

conditions.

Settlement

United States of 

America v. 

Nexway Sasu, et 

al.

1:23-cv00900District of 

Columbia

4/3/2023 Telemarketing 

Sales Rule 

Alleged the defendants worked 

with telemarketers who made 

misrepresentations to consumers 

about the performance and 

security of their computers in 

connection with the sale of bogus 

technical support services.

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 5 2

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

Cycra, Inc.

FTC Matter 

No. 2323007

FTC 

Administrative 

Matter

4/5/2023 Made In USA Alleged the defendants falsely 

claimed that the company’s 

products were manufactured in 

the U.S.

Consent 

Order

Federal Trade 

Commission, 

Office of the 

Attorney 

General, State 

of Florida v. 

Global ETrading LLC 

(Chargebacks91

1)

8:23-cv00795Middle District 

of Florida

4/12/2023 Unfairness Alleged the defendants used 

multiple unfair techniques to 

prevent consumers from 

successfully winning chargeback 

disputes.

Litigation 

Ongoing

Federal Trade 

Commission v. 

SL Finance 

LLC, et al.

8:23-cv00698Central 

District of 

California

4/24/2023 TSR/CCPA/Gra

mm-LeachBliley Act 

(GLB Act)

Alleged the defendants operated 

unlawful student loan debt relief 

schemes.

Litigation 

Ongoing

Federal Trade 

Commission v. 

BCO Consulting 

Services, Inc., et 

al.

8:23-cv00699Central 

District of 

California

4/24/2023 TSR/CCPA/ 

GLB Act

Alleged the defendants operated 

unlawful student loan debt relief 

schemes.

Litigation 

Ongoing
FEDERAL TRADE COMMISSION FTC.GOV 5 3

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

United States of 

America v. 

Xcast Labs, Inc.

23-cv-03646 Central 

District of 

California

5/12/2023 Telemarketing 

Sales Rule 

Alleged the defendant, a Voice 

Over Internet Protocol (VOIP) 

provider, assisted and facilitated 

the dialing of billions of calls that 

violated the Telemarketing Sales 

Rule (TSR).

Litigation 

Ongoing

United States of 

America v. 

Edmodo, LLC

3:23-cv02495Northern 

District of 

California

5/22/2023 Children’s 

Online Privacy 

Protection Rule 

Alleged the defendant collected 

personal data from children 

without obtaining their parent’s 

consent and used that data for 

advertising, in violation of the 

COPPA Rule, and unlawfully 

outsourced its COPPA 

compliance responsibilities to 

schools.

Settlement

Federal Trade 

Commission v. 

Ring LLC

1:23-cv-1549 District of 

Columbia

5/31/2023 Data 

Privacy/Securit

y

Alleged the defendant 

compromised its customers’ 

privacy by allowing any 

employee or contractor to access 

consumers’ private videos and by 

failing to implement basic 

privacy and security protections, 

enabling hackers to take control 

of consumers’ accounts, cameras, 

and videos.

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 5 4

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

United States of 

America v. 

Amazon.com, 

Inc., et al.

2:23-cv00811Western 

District of 

Washington

5/31/2023 Children’s 

Online Privacy 

Protection Rule 

Alleged the defendant violated 

the Children’s Online Privacy 

Protection Act Rule (COPPA 

Rule) and deceived parents and 

users of the Alexa voice assistant 

service about its data deletion 

practices.

Settlement

United States of 

America v. 

Microsoft 

Corporation

2:23-cv00836Western 

District of 

Washington

6/5/2023 Children’s 

Online Privacy 

Protection Rule 

Alleged the defendant violated 

COPPA by collecting personal 

information from children who 

signed up to its Xbox gaming 

system without notifying their 

parents or obtaining their parents’ 

consent, and by illegally retaining 

children’s personal information.

Settlement

Federal Trade 

Commission v. 

Vision Online, 

Inc. (dba 

Ganadores 

Online) et al.

6:23-cv01041Middle District 

of Florida

6/5/2023 Business 

Opportunity 

Rule/ 

CRFA/CoolingOff Rule

Alleged the defendants operated 

an ecommerce and real estate 

investment business opportunity 

scheme that targeted Spanishspeaking consumers with false 

money-making pitches.

Litigation 

Ongoing
FEDERAL TRADE COMMISSION FTC.GOV 5 5

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

1Health.io, 

Inc./Vitagene, 

Inc. 

FTC Matter 

No. 1923170

FTC 

Administrative 

Matter

6/16/2023 Data Privacy/

Security

Alleged the defendant left 

sensitive genetic and health data 

unsecured, deceived consumers 

about their ability to get their data 

deleted and changed its privacy 

policy retroactively without 

adequately notifying and 

obtaining consent from 

consumers whose data the 

company had already collected.

Consent 

Order

Federal Trade 

Commission v. 

Amazon.com, 

Inc.

2:23-cv-0932 Western 

District of 

Washington

6/21/2023 Restore Online 

Shoppers’ 

Confidence Act, 

Alleged the defendant used 

manipulative, coercive, or 

deceptive user-interface designs 

known as “dark patterns” to trick 

consumers into enrolling in 

automatically renewing Prime 

subscriptions and that Amazon 

knowingly complicated the 

cancellation process for Prime 

subscribers who sought to end 

their membership.

Litigation 

Ongoing

In the Matter of 

Chaucer 

Accessories, 

Inc.; Bates 

Accessories, 

Inc. et al.

FTC Matter 

No. 2223163

FTC 

Administrative 

Matter

6/26/2023 Made In USA Alleged the defendants falsely 

made claims that certain 

company products were 

manufactured in the U.S.

Consent 

Order
FEDERAL TRADE COMMISSION FTC.GOV 5 6

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Publishers 

Clearing House 

LLC

2:23-cv04735Eastern 

District of 

New York

6/26/2023 CAN-SPAM 

Act

Alleged the defendant used “dark 

patterns” to mislead consumers 

about how to enter the company’s 

well-known sweepstakes 

drawings and made them believe 

that a purchase is necessary to 

win or would increase their 

chances of winning, and that their 

sweepstakes entries are 

incomplete even when they are 

not.

Settlement

United States of 

America v. 

Michael J. 

Connors et al.

(Smoke Away)

2:23-cv00475Middle District 

of Florida

6/29/2023 Opioid 

Addiction 

Recovery Fraud 

Prevention Act 

Alleged the defendants 

deceptively marketed their 

Smoke Away products as able to 

eliminate consumers’ nicotine 

addiction and enable them to quit 

smoking quickly, easily, and 

permanently.

Settlement

United States of 

America v. 

Hello Hello 

Miami, LLC et 

al.

1:23-cv22553Southern 

District of 

Florida (Miami 

Division)

7/10/2023 Telemarketing 

Sales Rule 

Alleged the defendants assisted 

and facilitated illegal robocalls, 

including calls to consumers on 

the National Do Not Call 

Registry, and misrepresented 

themselves as representatives of 

Amazon.

Litigation 

Ongoing
FEDERAL TRADE COMMISSION FTC.GOV 5 7

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Celsius 

Network, Inc. et 

al.

1:23-cv06009Southern 

District of 

New York

7/13/2023 Gramm-LeachBliley Act Alleged the defendants misled 

consumers into transferring 

cryptocurrency onto the platform 

by falsely promising that deposits 

would be safe and always 

available.

Partial 

Settlement, 

Litigation 

Ongoing

United States of 

America, and 

State of Arizona 

v. Vision Solar 

LLC, Solar 

Xchange LLC, 

et al.

2:23-cv01387District of 

Arizona

7/14/2023 Telemarketing 

Sales Rule 

Alleged the defendants made 

misrepresentations during sales 

pitches and called consumers on 

the National Do Not Call 

Registry.

Partial 

Settlement, 

Litigation 

Ongoing

United States of 

America v. 

Viceroy Media 

Solutions, LLC 

d/b/a 

quickjobs.com, 

et al.

3:23-cv03516Northern 

District of 

California

7/14/2023 Telemarketing 

Sales Rule 

Alleged the defendants assisted 

and facilitated their partners 

placing millions of illegal 

robocalls that were based on 

leads and invalid consent 

gathered on the defendants' 

websites in violation of the TSR.

Settlement

United States of 

America v. 

Yodel 

Technologies, 

LLC et al.

8:23-cv-1575 Middle District 

of Florida 

(Tampa 

Division)

7/14/2023 Telemarketing 

Sales Rule 

Alleged the defendants violated 

the TSR by placing illegal calls to 

numbers on the National Do Not 

Call Registry and illegally 

placing calls with pre-recorded 

messages.

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 5 8

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

United States of 

America v. 

Fluent, LLC et 

al.

9:23-cv81045Southern 

District of 

Florida

7/17/2023 Telemarketing 

Sales Rule 

Alleged the defendants used false 

or misleading promises of job 

opportunities or valuable items to 

induce consumers to divulge 

personal information on their 

websites and then sold this 

information to third parties that 

used it to bombard consumers 

with unwanted robocalls, spam 

text messages, and commercial 

emails.

Settlement

Federal Trade 

Commission v. 

Rejuvica LLC, 

et al.

8:23-cv01286Central 

District of 

California

7/18/2023 Opioid 

Addiction 

Recovery Fraud 

Prevention Act 

Alleged the defendants made 

false claims that their product 

reduced or eliminated cravings 

for alcohol and that it enabled 

consumers to reduce their alcohol 

consumption or quit drinking 

completely.

Settlement

United States of 

America v. 

ConsumerInfo.c

om, Inc.

8:23-cv01494Central 

District of 

California

08/14/2023 CAN-SPAM 

Act

Alleged the defendants violated 

the CAN-SPAM Act by sending 

consumers marketing offers 

without providing clear and 

conspicuous notice of a 

consumer’s right to opt out of 

receiving marketing messages or 

a mechanism to opt out.

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 5 9

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Automators 

LLC, et al.

3:23-cv01444Southern 

District of 

California

08/08/23 Business 

Opportunity 

Rule/CRFA

Alleged the defendants promised 

consumers high returns as 

“passive investors” in profitable 

e-stores powered by artificial 

intelligence.

Litigation 

Ongoing

Federal Trade 

Commission v. 

Intercontinental 

Solutions LLC, 

et al.

8:23-cv01495Central 

District of 

California

08/14/23 TSR/GLB Alleged the defendants pretended 

an affiliation with the U.S. 

Department of Education to make 

deceptive promises about student 

loan forgiveness programs that 

cost consumers millions in illegal 

upfront fees.

Litigation 

Ongoing

Federal Trade 

Commission v. 

KW Technology 

Inc., et al.

1:23-cv06633Eastern 

District of 

New York

9/6/23 COVID-19 

Consumer 

Protection Act

Alleged the defendants made 

false and deceptive claims about 

their product named "the 

Invisible Mask," which they 

stated prevented COVID-19.

Litigation 

Ongoing

Federal Trade 

Commission v. 

Instant 

Checkmate, 

LLC, et al.

3:23-cv01674Southern 

District of 

California

09/11/23 Fair Credit 

Reporting Act 

(FCRA)/ 

Deceptive 

Advertising and 

Endorsement 

Claims 

Alleged that defendants sold 

background reports to consumers 

and made numerous deceptive 

claims, including that the reports 

were the most accurate reports 

available, that individuals had 

criminal records when they did 

not, and that consumers could 

remove inaccurate information in 

the background reports.

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 6 0

Case Name Case 

Number

Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Hey Dude, Inc.

2:23-cv-1412 District of 

Nevada

09/11/23 Deceptive 

Endorsement 

Claims/Mail, 

Internet, or 

Telephone 

Order 

Merchandise 

Rule

Alleged that defendant misled 

consumers by suppressing 

negative reviews, and failed to 

respond appropriately when they 

were unable to ship consumers’ 

orders on time.

Settlement

Federal Trade 

Commission v. 

Lurn, Inc., et al.

8:23-cv02622District of 

Maryland

09/27/23 Deceptive 

Earnings 

Claims/TSR/ 

Notice of 

Penalty 

Offenses

Alleged the defendants used 

deceptive and unsubstantiated 

earnings claims to sell consumers 

business coaching services.

Settlement
Federal Trade Commission

ftc.gov