The U.S. SAFE WEB Act 

and the FTC’s Fight 

Against Cross-Border 

Fraud

A Report to Congress

October 20, 2023

FEDERAL TRADE COMMISSION

Lina M. Khan, Chair

Rebecca Kelly Slaughter, Commissioner

Alvaro M. Bedoya, Commissioner
Contents 

Executive Summary ............................................................................................................ i

Introduction........................................................................................................................ 1

Report Overview ............................................................................................................................... 2

I. Cross-Border Fraud................................................................................................... 3

II. Responding to the Scourge of Cross-Border Fraud ............................................... 9

A. Early FTC Responses to Cross-Border Fraud .......................................................................... 9

B. Cross-Border Enforcement Cases ........................................................................................... 12

C. Use of SAFE WEB Cooperation Tools .................................................................................. 16

1. Sharing of Confidential and Compelled Information with Foreign Agencies ....................... 18

2. Investigative Assistance to Foreign Law Enforcement Agencies ......................................... 23

3. International Cooperation Agreements .................................................................................. 26

4. International Staff Exchanges ................................................................................................ 27

5. Other SAFE WEB Cooperation and Benefits ........................................................................ 29

III. Recommendations for Congress.............................................................................29

Conclusion.........................................................................................................................31

Acknowledgments ............................................................................................................32

Appendix A .......................................................................................................................33

Additional Details on Cross-Border and International Fraud Data ................................................. 33

Appendix B........................................................................................................................43
Consumer Sentinel and Tableau Public .......................................................................................... 43

Consumer Sentinel ........................................................................................................................ 43

How the FTC Receives Complaints .............................................................................................. 43

How the FTC Uses Complaints .................................................................................................... 44

Tableau Public Page ...................................................................................................................... 45

Appendix C .......................................................................................................................48

FTC Enforcement Actions with Public Cross-Border Components ............................................... 48
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The Federal Trade Commission (“FTC” or “Commission”) submits this report to update Congress on 

implementation of the U.S. SAFE WEB Act of 2006, as required by the 2020 law that extended the Act 

until September 30, 2027.1 As directed by Congress, this report describes the FTC’s use of and 

experience with the Act, including the number of cross-border complaints received, the foreign agencies 

with which the FTC has cooperated, foreign FTC litigation, and legislative recommendations based on 

that experience. This report supplements the FTC’s 2009 report to Congress on the FTC’s first three 

years of experience in implementing the Act.2

Executive Summary

In 2006, recognizing the increasing threats facing consumers in the global marketplace, Congress passed 

the Undertaking Spam, Spyware, And Fraud Enforcement with Enforcers beyond Borders Act of 2006: 

the U.S. SAFE WEB Act (“SAFE WEB”).3 Since then, SAFE WEB has become an indispensable tool 

helping the FTC to combat cross-border fraud, and to otherwise protect consumers in an increasingly 

global and digital economy. It is critical that the FTC have these tools to continue fighting such 

fraud and other misconduct, which continues to cost American consumers billions of dollars.

SAFE WEB expressly affirms the FTC’s authority to pursue deceptive or unfair acts or practices 

involving foreign actors targeting Americans, as well as U.S. business conduct affecting foreign 

consumers. It also provides the FTC with enhanced law enforcement tools essential to effective crossborder enforcement and cooperation, including in the areas of (1) information sharing, (2) investigative 

assistance, (3) jurisdictional authority, (4) confidentiality, and (5) enforcement relationships. 

Since SAFE WEB’s passage, the FTC has used the Act to:

• Share confidential and compelled information from FTC files in 175 instances with 43 law 

enforcement agencies in 20 different countries.

• Provide investigatory assistance by issuing more than 140 civil investigative demands (“CIDs”) 

in 67 investigations on behalf of 21 foreign agencies from eight countries.

• Pursue cross-border enforcement matters facilitated by information sharing and cooperation with 

foreign law enforcement agencies.

• Engage in 148 staff exchanges to build cooperation with foreign counterparts, in particular 

bringing colleagues from more than 41 foreign jurisdictions to work with FTC attorneys, 

economists, investigators, and more, and sending FTC staff on 15 short-term secondments.

1 Pub. L. No. 116-173, 134 Stat. 837 (2020), available at https://www.congress.gov/116/plaws/publ173/PLAW116publ173.pdf. 2 The U.S. SAFE WEB Act: The First Three Years. A Report to Congress (Dec. 2009) (“2009 SAFE WEB Report”), 

https://www.ftc.gov/reports/us-safe-web-act-first-three-years-federal-trade-commission-report-congress. 3 Pub. L. No. 109-455, 120 Stat. 3372 (2006) (codified in scattered sections of 15 U.S.C. and 12 U.S.C. § 3412(e)), available 

at http://uscode.house.gov/statutes/pl/109/455.pdf.
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With SAFE WEB, the FTC has pursued and stopped harmful conduct in the U.S. and successfully 

defended against challenges to its jurisdictional authority over foreign companies targeting American 

consumers. The FTC has also worked with numerous foreign enforcers to stop cross-border injury and 

frauds. For example, SAFE WEB enabled the FTC to: 

• Shut down a real estate investment scam (known as “Sanctuary Belize”) that took in more than 

$100 million, the largest such scheme the FTC has ever targeted.

• Cooperate with privacy authorities in Canada and the United Kingdom (“U.K.”) to pursue 

actions against AshleyMadison.com, an online dating site that deceived consumers and failed to 

protect the account and profile information of more than 36 million individuals. 

• Work with foreign law enforcement agencies to stop fraudulent money transfers to Western 

Union and MoneyGram locations in Spain in connection with a Nigerian email scam.

SAFE WEB has been instrumental in the FTC’s fight against cross-border fraud, which continues to 

plague consumers and shows no sign of abating. Since the FTC first began tracking cross-border fraud 

complaints in 1996, the FTC has received over 2.6 million consumer reports of cross-border fraud. In 

the preceding eight and half years from January 1, 2015, to June 30, 2023, alone, consumers reported: 

• Over 1.4 million incidents of cross-border fraud.

• More than $5.2 billion in losses. 

During those same eight and a half years, American consumers in particular reported:

• Nearly half a million incidents of cross border fraud. 

• $2.49 billion in losses to cross-border fraud.

These figures, already staggering, almost certainly understate the true amount of cross-border fraud that 

consumers face. Only a small percentage of consumers who encounter fraud file complaints, and the 

cross-border aspects of many frauds are not always apparent to the consumers themselves.

SAFE WEB has also become a key part of international enforcement arrangements to protect privacy in 

connection with the international data transfers that are an increasingly common part of the consumer 

marketplace.4 The FTC plays an enforcement role in protecting the transfer of personal data from 

4 See, e.g., U.S. Department of Commerce, Data Privacy Framework Program, EU-U.S. Data Privacy Framework Principles, 

https://www.dataprivacyframework.gov/s/framework-text (last accessed Sept. 28, 2023); See also Section II.B. (discussing 

CafePress).
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numerous foreign countries. These data transfers in turn support trillions of dollars in cross-border 

commercial transactions.5

Given the magnitude of the cross-border issues and the important role that SAFE WEB plays in the 

FTC’s response, we recommend permanent reauthorization of the Act. Allowing SAFE WEB to lapse 

would deprive the FTC of its most important tool to fight cross-border fraud and put at risk the FTC’s 

cross-border enforcement efforts.

5 See White House, Fact Sheet: United States and European Commission Announce Trans-Atlantic Data Privacy Framework 

(Mar. 25, 2022), https://www.whitehouse.gov/briefing-room/statements-releases/2022/03/25/fact-sheet-united-states-andeuropean-commission-announce-trans-atlantic-data-privacy-framework/. 
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Introduction

Cross-border fraud remains a serious and persistent problem in the United States. Since 1999, the FTC 

has received over 1.3 million reports of cross-border fraud from U.S. consumers. 

The U.S. SAFE WEB Act serves as a vital tool in the FTC’s arsenal to fight cross-border fraud and 

protect consumers from unfair and deceptive acts and practices. SAFE WEB expressly affirms the 

FTC’s authority to pursue foreign conduct that causes reasonably foreseeable injury to American 

consumers, or that involves material conduct here in the United States.6 SAFE WEB also promotes 

global partnerships and enforcement cooperation with foreign counterparts. The Act provides a 

framework to engage in cross-border assistance, including information sharing7 and investigative 

support.8 Further, the Act encourages broader cross-border cooperation with law enforcement agencies 

around the world through agreements, memoranda of understanding (“MOUs”),9 and staff exchanges.10

The record of activities since our last report to Congress in 200911 shows that SAFE WEB has met 

Congress’s objective to provide more effective cross-border consumer protection enforcement. 

The FTC has been tracking and combatting cross-border fraud for nearly three decades. During that time 

the nature and origins of cross-border fraud have evolved, and cross-border fraud continues to cause 

significant harm to consumers. In 1996, the earliest year for which the FTC has cross-border fraud data, 

less than 1% of fraud reported to the FTC was cross-border.12 Nearly 30 years later, in 2022, the most 

recent full year for which the FTC has complaint data, over 11% of all fraud reported to the FTC was 

cross-border, with consumers reporting fraud originating in 225 countries. Since 2006, the year 

Congress passed the U.S. SAFE WEB Act, U.S. consumers alone have reported over 1.14 million

instances of cross-border fraud and more than $4.4 billion in financial losses. 

The important tools Congress provided to the FTC through SAFE WEB have enabled the FTC to better 

protect consumers from cross-border fraud. In the 16 years since Congress passed SAFE WEB, the FTC 

has used the Act’s powers to assist or share information with foreign law enforcement in over 300

instances. The FTC has also brought at least 145 enforcement actions with a cross-border element. 

6 Section 3 of the SAFE WEB Act codified at Section 5(a) of the FTC Act, 15 U.S.C. §45(a)(4)(A) (providing that “unfair 

and deceptive acts and practices” includes those that “(i) cause or are likely to cause reasonably foreseeable injury within the 

United States; or (ii) involve material conduct occurring within the United States.”) 

7 Sections 4(a) and 6(a) of the SAFE WEB Act codified at Sections 6(f) and 21(b)(6) of the FTC Act, 15 U.S.C. §46(f) and 

57b-2(b)(6). 8 Section 4(b) of the SAFE WEB Act codified at Section 6(j) of the FTC Act, 15 U.S.C. §46(j). 9 FTC MOUs and other cooperation arrangements, including international agreements, are available at FTC, Legal Library: 

Cooperation Agreements, https://www.ftc.gov/legal-library/browse/cooperation-agreements (last accessed Sept. 28, 2023). 10 Section 9 of the SAFE WEB Act codified at Section 25A of the FTC Act, 15 U.S.C. § 57c-1 (authorizing the FTC “to 

retain or employ officers or employees of foreign government agencies on a temporary basis as employees of the 

Commission”).

11 2009 SAFE WEB Report, https://www.ftc.gov/reports/us-safe-web-act-first-three-years-federal-trade-commission-reportcongress). 12 Id. at 2 (reporting a total of 1,128 complaints).
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These enforcement actions have been supported, either directly or indirectly, by SAFE WEB’s 

promotion of cross-border engagement with foreign partners. 

Report Overview

In this report, the FTC provides data on cross-border fraud and its use of the authority Congress granted 

to the Commission through SAFE WEB. This report, provided more than a decade after the FTC first 

reported to Congress on SAFE WEB, reflects the FTC’s ongoing analysis of cross-border fraud, and its 

further experience with the tools provided under the Act. The report is organized as follows: 

Section I of the report discusses the multi-billion-dollar scourge of cross-border fraud and its impact on 

consumers, as shown in particular through analysis of cross-border complaint data. Appendix A

provides further details on international fraud complaint data. Appendix B provides further details about 

(a) the Consumer Sentinel Network – the FTC’s system for collecting and sharing consumer complaints;

(b) FTC actions to expand the system’s data contributors and enforcement users; and (c) the FTC’s 

public reporting of international complaint trends through its Tableau Public webpages.13

Section II of the report discusses how Congress and the FTC have responded to this challenge. Section 

II.A. describes some of the FTC’s early efforts to combat cross-border fraud and how those efforts led to 

the FTC recommending, and Congress passing, the U.S. SAFE WEB Act. It also describes the key 

enforcement tools Congress granted to the FTC through SAFE WEB. 

Section II.B. highlights the FTC’s cross-border enforcement activities since SAFE WEB’s passage. 

These actions demonstrate the importance of SAFE WEB’s express affirmation of the FTC’s authority 

to pursue deceptive or unfair acts or practices involving foreign commerce. Appendix C provides a list 

of FTC enforcement actions with public cross-border components since Congress passed the Act. The 

cases listed cover a broad range of subjects, ranging from fraud, spam, and spyware to deceptive 

advertising, data security, and privacy.

Section II.C. details how the FTC regularly uses SAFE WEB to increase cross-border enforcement 

cooperation to help protect consumers from cross-border fraud and other misconduct. It explains FTC 

efforts to share information with and assist foreign law enforcement, highlighting notable enforcement 

examples. It also explains how the FTC has relied on SAFE WEB to grow and deepen our relationships 

with foreign law enforcement agencies and various international networks, including through MOUs and 

staff exchanges. 

13 Consumer Sentinel has a five-year data retention policy, with reports older than five years purged biannually. When the 

FTC drafted this report, it maintained Sentinel data for January 1, 2019, to June 30, 2023 (published July 25, 2023). This 

report relies on that data, historical reports, and limited archived data currently retained by the FTC, including for the period 

January 1, 2015, to December 31, 2018. Certain current Sentinel data that the FTC makes public on a quarterly basis is 

available at https://public.tableau.com/app/profile/federal.trade.commission/viz/federal.trade.commission#!/. Certain 

historical Sentinel reports are available at https://www.ftc.gov/enforcement/consumer-sentinel-network/reports.
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

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Section III of the report provides the FTC’s legislative recommendation. The FTC again urges Congress 

to make SAFE WEB permanent by removing the sunset provision currently set to expire on September 

30, 2027, thereby preserving the Commission’s jurisdiction over foreign commerce and its ability to 

effectively cooperate with foreign law enforcement. As shown in this report, the U.S. SAFE WEB Act 

and its tools have been essential to the FTC’s efforts to combat cross-border fraud and other consumer 

harms. Without these tools, the FTC’s ability to cooperate and share information with foreign law 

enforcement agencies would be severely curtailed, putting at risk the Commission’s ability to stop unfair 

or deceptive acts or practices involving foreign commerce. The FTC also urges Congress to amend 

Section 13(b) of the FTC Act to restore the FTC’s ability to provide refunds to harmed consumers and 

prevent bad actors from keeping money generated by breaking the law.

I. Cross-Border Fraud

Consumer complaints collected by the FTC demonstrate that cross-border fraud is significant and 

persistent.14 Since 1996, when the FTC first began tracking cross-border complaints, the FTC has 

received over 2.6 million reports of cross-border fraud,15 including over 1.4 million since January 1, 

2015. American consumers alone have reported over 1.3 million incidents of cross-border fraud since 

1999 (the earliest that data specific to U.S. consumers is available to the FTC), including 1.14 million

since 2006 (when Congress passed SAFE WEB) and 482,600--nearly half a million--since January 1, 

2015.16

While significant on its own, cross-border fraud also accounts for a notable portion of the total fraud that 

consumers face. Since the FTC’s 2009 SAFE WEB Report (from January 1, 2009, to June 30, 2023), 

nearly 10% of all fraud reports received by the FTC were cross-border, including 12.5% and 11.4% of 

14 The FTC considers a complaint to be “cross-border” when the consumer country is provided, the company country is 

provided, and those countries are different. Prior to 2013, the FTC considered a complaint to be cross-border if: (1) a U.S. 

consumer complained about a company located in a country other than the U.S., (2) a Canadian consumer complained about 

a company located in a country other than Canada, or (3) a consumer located in a country other than the U.S. or Canada 

complained about a company located in the U.S. or Canada. This excluded a small number of complaints where both the 

consumer and company location were in countries other than the U.S. or Canada. 

15 The FTC received 542,885 cross-border fraud complaints from January 1, 1996, to December 31, 2008. (See 2009 SAFE 

WEB Report at 5.) Between January 1, 2009, and June 30, 2023, the FTC received an additional 2,131,592 cross-border fraud 

complaints. (See Figure 1). 16 U.S. consumers filed 500,251 cross-border fraud reports between January 1, 1999, and December 31, 2009. See Prepared 

Statement of the Federal Trade Commission on Reauthorizing the U.S. SAFE WEB Act of 2006 before the Subcommittee on 

Commerce, Manufacturing, and Trade of the Committee on Energy and Commerce, United States House of Representatives

by Hugh Stevenson, Deputy Director, Office of International Affairs (July 12, 2012) (“July 2012 Prepared Statement of Hugh 

Stevenson”) at 3, https://www.ftc.gov/legal-library/browse/prepared-statement-federal-trade-commission-reauthorizing-ussafe-web-act-2006. U.S. consumers filed 381,260 reports between January 1, 2010, and December 31, 2014. See FTC, 

Consumer Sentinel Network, International Consumer Complaints, January – December 2014 (June 2015) at 7, 

https://www.ftc.gov/system/files/documents/reports/international-consumer-complaints-cy-2014/cy-2014_international.pdf

(providing data on fraud complaints by U.S. consumers against foreign businesses for calendar years 2010 to 2014). Between 

January 1, 2015, and June 30, 2023, U.S. consumers reported the following number of cross-border fraud complaints: 51,408

(2015); 56,923 (2016); 52,829 (2017); 50,800 (2018); 45,194 (2019); 69,184 (2020); 73,894 (2021); 56,117 (2022); 26,251 

(through June 30, 2023). 
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complaints filed in 2021 and 2022, respectively.17 In addition, in 2021 and 2022, roughly one in five of 

the fraud reports that reported both a consumer and a business location were cross border.18 The number 

of cross-border fraud complaints the FTC received each year since 2009, plus partial year data for 2023, 

appears in Figure 1.

19 

Figure 1: Cross Border Complaint Count 

Cross-border fraud results in significant financial harm to consumers. Since 2006, U.S. consumers have 

reported over $4.4 billion dollars in losses to cross border fraud.20 This includes $2.49 billion since 

17 Between January 1, 2009, and June 30, 2023, the FTC received 22,309,302 fraud complaints. In 2021 and 2022, the FTC 

received 2,923,241 and 2,369,527 fraud complaints, respectively. See Figure 1 for cross-border fraud data. 18 If consumers do not report their location or the location of the business, the FTC cannot accurately categorize their reports

as cross-border or non-cross-border. In 2021 and 2022, it was “unknown” whether 38% and 39% of consumer reports, 

respectively, were cross-border or non-cross border. 19 The increase in cross-border fraud reports in 2021 reflects, in part, a significant number of new reports from a recently 

added data contributor located outside of the U.S. Additionally, the increase in cross-border fraud reports in 2021 and 

subsequent decrease in 2022 is consistent with all fraud complaints and is likely related, in part, to the COVID-19 global 

pandemic.

20 U.S. consumers reported $1.4 billion in losses to cross-border fraud between January 1, 2006, and December 31, 2011. See

July 2012 Prepared Statement of Hugh Stevenson at 3. U.S. consumers reported $578 million in losses from January 1, 2012, 

to December 31, 2014. See Consumer Sentinel Network, International Consumer Complaints, January – December 2014 92,896 109,457 139,266 116,396 105,677 98,181 81,600 89,280 114,391 119,648 117,483163,813 365,731 269,017 297,512

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

YTD

January 1, 2009 to June 30, 2023
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January 1, 2015.21 In addition, when reporting about cross-border fraud, most U.S. consumers (between 

62% and 76% each year from 2015 to 2022) have reported a financial loss,22 with annual median 

reported losses ranging from $141 to $511. Total annual and median reported losses by U.S. consumers 

to cross-border fraud for the years 2015 to 2022 are set forth in Figure 2. U.S. consumers also reported 

an additional $299.4 million in losses to cross-border fraud during the first half of 2023 – more than the 

total annual losses reported by U.S. consumers to cross-border fraud each year between 2015 and 2020. 

Figure 2: Reported U.S. Consumer Loss to Cross-Border Fraud

These figures, while staggering, almost certainly understate the true extent of cross-border fraud. This is 

because consumers report only a small percentage of scams to government agencies or other 

organizations, such as the Better Business Bureaus (“BBBs”), that contribute data to the FTC’s 

(FTC, June 2015) at 9 (providing data on amount paid by U.S. consumers against foreign companies for calendar years 2012 

to 2014), https://www.ftc.gov/enforcement/consumer-sentinel-network/reports. Since January 1, 2015, U.S. consumers have 

reported $2.49 billion in losses to cross-border fraud. See Figure 2. 21 For this same period, all consumers (both U.S. and foreign) have reported the following annual losses to cross-border 

fraud, which totals over $5.2 billion: $137.8M (2015); $141.8M (2016); $168.6M (2017); $243.2M (2018); $406.3M (2019); 

$619.9M (2020); $1.289B (2021); $1.557B (2022); $693.9M (through June 30, 2023). 22 Since January 1, 2015, the following percentage of U.S. consumers have reported a financial loss when reporting about 

cross-border fraud: 70% (2015); 71% (2016); 62% (2017); 67% (2018); 63% (2019); 76% (2020); 70% (2021); 65% (2022). 

73M 75M 86M

132M

188M

271M

582M

784M

598M

2015 2016 2017 2018 2019 2020 2021 2022 2023

YTD

Total Losses

Annual Reported Losses

January 1, 2015 - June 30, 2023

Median Loss: $500 | $500 | $390 | $310 | $310 | $141 | $307 | $511 | $400
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Consumer Sentinel system.23 In addition, when reporting fraud, consumers may not even know that a 

foreign entity is involved.24 Foreign scammers often mislead consumers about or conceal their locations, 

including by using phone numbers that appear to be from the U.S.,25 VoIP technology such as spoofing 

(i.e., transmitting fake caller ID information),26 fake social media profiles,27 and other tactics. 

Companies with a foreign connection may also conceal a connection with an additional foreign country 

or with the United States. The FTC’s enforcement action against Best Priced Brands (see Section II.B., 

infra) illustrates how simple tactics can easily confuse consumers as to a company’s location.

U.S. consumers also continue to encounter fraud from businesses operating from jurisdictions around 

the world.28 Since 2019, consumers have reported fraud connected with 231 different countries. The top 

10 countries identified by U.S. consumers in connection with their fraud complaints for the period 

between January 1, 2019, and June 30, 2023, combined (during which this detailed data is currently 

available) is set forth in Figure 3. This includes China,29 Canada, the U.K., India, and Mexico, which 

23 See, e.g., Keith B. Anderson, To Whom Do Victims of Mass-Market Consumer Fraud Complain? (May 24, 2021), 

https://ssrn.com/abstract=3852323 or http://dx.doi.org/10.2139/ssrn.3852323 (finding that, based on data from surveys of 

mass-market consumer fraud sponsored by the FTC in 2005, 2011, and 2017, in about 45% of instances, victims complained 

to someone beyond their family or friends, most frequently to someone directly involved in the transaction, such as the seller 

or manufacturer, a bank, or credit card company, but only 4.8% of victims complained to a BBB or government agency); See

also, e.g., Morgan, Rachel E., U.S. Department of Justice, Office of Justice Programs, Bureau of Justice Statistics, Financial 

Fraud in the United States, 2017, Bulletin NCJ255817 (April 2021), https://bjs.ojp.gov/content/pub/pdf/ffus17.pdf (finding 

that about 14% of victims of financial fraud reported the fraud to the police, about 12% reported to state or local consumer 

agencies, such as a state attorney general’s office or the BBB, and 10% reported to a federal consumer agency such as the 

FTC); U.S. Attorney’s Office, W.D. Wash., Financial Fraud Crime Victims (Feb. 10, 2015), https://www.justice.gov/usaowdwa/victim-witness/victim-info/financial-fraud (estimating that only 15% of fraud victims report their crimes to law 

enforcement); and U.K. National Crime Agency, https://www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/fraudand-economic-crime (last accessed Sept. 15, 2023) (estimating that 86% of fraud instances in England and Wales go 

unreported).

24 For example, between 18% and 39% of fraud complaints received by the FTC between 2019 and 2022 could not be 

identified as either cross-border or non-cross border. See also supra note 19. 25 See, e.g., Colleen Tressler, “One-ring” cell phone scam can ding your wallet, FTC (Feb. 10, 2024), 

https://consumer.ftc.gov/consumer-alerts/2014/02/one-ring-cell-phone-scam-can-ding-your-wallet (alerting consumers that 

scammers are using auto-dialers to call consumers from international phone numbers, often in the Caribbean, that appear to 

come from the U.S.). See also, e.g., AARP, Scammers Lurk Behind Area Code 876 (Sept. 17, 2012), 

https://www.aarp.org/money/scams-fraud/info-09-2012/beware-area-code-876-nh1788.html. 26 See Federal Communications Commission, Caller ID Spoofing, https://www.fcc.gov/spoofing (last accessed Sept. 15, 

2023) (“when a caller deliberately falsifies the information transmitted to your caller ID display to disguise their identity”). 

See also, e.g., FTC v. Alcazar Networks Inc., No. 6:20-cv-2200 (M.D. Ga. Dec. 3 2020), https://www.ftc.gov/legallibrary/browse/cases-proceedings/1923259-alcazar-networks-inc (alleging that the defendants facilitated tens of millions of 

illegal telemarketing phone calls, including some calls from overseas and some that displayed spoofed caller ID numbers; 

How To Avoid Phone Scams: Don't Trust Caller ID Infographic, FTC (June 2023), https://consumer.ftc.gov/articles/howavoid-phone-scams-dont-trust-caller-id-infographic. 27 See, e.g., FTC, What to Know About Romance Scams (Aug. 2022), https://consumer.ftc.gov/articles/what-know-aboutromance-scams (reporting that romance scammers create fake profiles on social media sites); see also, e.g., Emma Fletcher, 

Data Spotlight: Reports of romance scams hit record highs in 2021, FTC (Feb. 2022), https://www.ftc.gov/news-events/datavisualizations/data-spotlight/2022/02/reports-romance-scams-hit-record-highs-2021. 28 In 2009 the FTC reported that consumer complaints in Sentinel identified companies with connections to over 200 

countries. (2009 SAFE WEB Report at 5).

29 In this report, data for China includes Hong Kong and Macau, which are tracked separately in Sentinel. 
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combined accounted for more than 55% of cross-border fraud reported by U.S. consumers during this 

period. 

Figure 3: Top 10 Countries for Cross-Border Fraud as Reported by 

U.S. Consumers

As detailed in Appendix A, recent cross-border fraud reports also show that cross-border problems are 

multifaceted, with the issues that U.S. consumers are most likely to encounter varying by the foreign 

country involved. In addition, international fraud reports30 show that consumers are contacted by and 

transfer funds to scammers outside of the U.S. in a number of different ways, with the frequency of 

payment methods also varying by country. 

For example, U.S. consumers have reported that two of the most prevalent problems between January 1, 

2019, and June 30, 2023, were those related to online shopping (e.g., undisclosed costs, failure to deliver 

30 A fraud complaint is considered to be international when the consumer country or the company country is reported as not 

the U.S., regardless of any other information.

All other countries 

combined, 86,610

31%

China, 69,372

25%

Canada, 35,375

13%

UK, 21,281

8%

India, 16,446

Mexico, 13,320

Philippines, 11,334

Nigeria, 9,158

Jamaica, 7,860 Dominican Republic, 5,537

January 1, 2019 - June 30, 2023 

5%

4%

3% 3% 2%

6%
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 8

on time, non-delivery, etc.) and romance scams.31 U.S. consumers have also reported the following in 

recent years:

• Online shopping scams frequently originate in China or Canada. 

• They often face online shopping and miscellaneous investment frauds (such as virtual 

currencies and investment advice and seminars) involving entities in the U.K. 

• Imposter scams, such as tech support, business imposter, and romance scams, often are 

connected to India and the Philippines.

• When consumers face fraud from Mexico, it’s often friend and family imposter scams. 

Recent international fraud reports also show that the means through which scammers contact and obtain 

funds from consumers has continued to evolve. For example, such reports show: 

• Consumers have increasingly been targeted through social media platforms.32 Increased 

contact through social media platforms is especially prevalent for fraud originating in China, 

the U.K., and Mexico, less so for fraud originating in India and Canada. 

• Wire transfers continue to be a common method of payment for cross-border fraud. This is 

often true for fraud originating in Canada and Mexico, but less so for fraud originating in 

China (excluding Hong Kong and Macau), where most consumers (over 70%) report paying 

fraudsters through credit or debit cards. Similarly, consumers also regularly report paying 

scammers in India using payment apps and paying scammers in the U.K. and Hong Kong 

using cryptocurrency.

And cross-border fraud doesn’t just harm American consumers. As some recent enforcement actions 

demonstrate, entities operating from the U.S. also injure consumers abroad. (See Section II.B. discussing 

Best Priced Brands and Fashion Nova.) In fact, since 2019, over 61% of all cross-border complaints 

received by the FTC (a total of 674,133 complaints) were filed by foreign consumers about U.S. entities.

31 Consumer Sentinel Network report definitions are available at FTC, Consumer Sentinel Network, 

https://www.ftc.gov/system/files/attachments/data-sets/category_definitions.pdf (last accessed Sept. 28, 2023) and FTC, 

Consumer Sentinel Network Subcategory Definitions (May 2023), 

https://www.ftc.gov/system/files/ftc_gov/pdf/CSNPSCFullDescriptions.pdf. 32 See Emma Fletcher, Data Spotlight: Social media a gold mine for scammers in 2021, FTC (Jan. 25, 2022), 

https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2022/01/social-media-gold-mine-scammers-2021; Press 

Release, FTC, FTC Issues Orders to Social Media and Video Streaming Platforms Regarding Efforts to Address Surge in 

Advertising for Fraudulent Products and Scams (Mar. 16, 2023), https://www.ftc.gov/news-events/news/pressreleases/2023/03/ftc-issues-orders-social-media-video-streaming-platforms-regarding-efforts-address-surge-advertising.
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 9

Such data highlights that cross-border fraud is nuanced and constantly evolving.33 While the FTC does 

not act on individual complaints, the complaint data collectively has been critical to identifying 

problems to address and supports the development of critical evidence in many cases.

II. Responding to the Scourge of Cross-Border 

Fraud

The FTC has responded forcefully to the problem of cross-border fraud and has worked on a range of 

issues affecting consumers in the increasingly global consumer marketplace.

A.Early FTC Responses to Cross-Border Fraud

Having observed key developments in technology and global trade and recognizing the possibilities for 

consumer harm, the FTC began taking early and concrete steps starting in the 1990s to protect 

consumers from cross-border fraud. Thus in 1992, the FTC helped to found what is now known as the 

International Consumer Protection and Enforcement Network (“ICPEN”) – a network of consumer 

authorities from various countries dedicated to strengthening cooperation on consumer protection 

enforcement.34 The FTC also began building cooperative partnerships with its Canadian counterparts. 

These efforts resulted in the United States entering into an agreement with Canada on deceptive 

marketing practices – the FTC’s first foreign agreement addressing consumer protection.35 The FTC also 

participated in a joint U.S.-Canada working group that prepared a 1997 report on cross-border 

telemarketing fraud, which recommended that regional task forces be established to maximize 

cooperation on cross-border fraud, and that governments and agencies examine their laws with an eye 

toward expanding shared access to cross-border information systems.36 Consistent with that report, the 

FTC began building relationships with Canadian federal and provincial authorities through regional 

33 See also, e.g., Office of the United Nations High Commissioner for Human Rights, Online Scam Operations and 

Trafficking in Forced Criminality in Southeast Asia: Recommendations for a Human Rights Response (2023), 

https://bangkok.ohchr.org/wp-content/uploads/2023/08/ONLINE-SCAM-OPERATIONS-2582023.pdf (discussing online 

scam operations and their link to human trafficking in Southeast Asia). 

34 Information on ICPEN, including its members, is available at ICPEN, About, https://icpen.org/who-we-are (last accessed 

Sept. 28, 2023).

35 Agreement Between the Government of the United States of America and the Government of Canada Regarding the 

Application of their Competition and Deceptive Marketing Practices Laws (Aug. 3, 1995), reprinted at 4 Trade Reg. Rep. 

(CCH) ¶ 13,503, available at https://www.ftc.gov/system/files/attachments/international-competition-consumer-protectioncooperation-agreements/agree_canada.pdf. 36 Report of the Canada - United States Working Group on Telemarketing Fraud, https://www.justice.gc.ca/eng/rp-pr/otherautre/tf/index.html (last accessed Sept. 28, 2023); See also Press Release, U.S. Department of Justice, U.S. and Canada Label 

Telemarketing Fraud Serious Economic Crime and Propose Recommendations to Fight Growing Problem (Nov. 20, 1997), 

https://www.justice.gov/archive/opa/pr/1997/November97/491crm.htm.html#:~:text=The%20report%20states%20that%20tel

emarketing,or%20to%20misrepresent%20the%20true. 
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 10

partnerships and task forces, such as the Toronto Strategic Partnership37 and Project COLT.38 In 1997, 

the FTC also launched Consumer Sentinel – the first bi-national (U.S. and Canada), multi-state 

consumer fraud database to track consumer complaints in multiple jurisdictions.39 In 2001, the FTC then 

joined with other consumer authorities to launch econsumer.gov – an ICPEN project now available in 

nine languages – where consumers could report international scams online and learn about other steps to 

combat fraud.

By the early 2000s, these and other FTC efforts had yielded important enforcement results. By 2001, 

when the FTC testified before the U.S. Senate, Committee on Governmental Affairs, Subcommittee on 

Investigations on cross-border fraud, the FTC had already brought multiple cross-border actions, 

including against sweepstake, advance-fee loan, and foreign lottery telemarketing scams emanating from 

Canada.40 This included the FTC’s first action against a foreign telemarketing operation for violating the 

Telemarketing Sales Rule (16 C.F.R. Part 310).41 And, by the mid-2000s, the FTC had extended its 

participation in Canada regional partnerships and reached various other agreements and MOUs 

concerning consumer protection, including with agencies in Australia, Ireland, Mexico, and Spain.42

Sentinel had also expanded to share econsumer.gov complaint data with other foreign enforcement 

agencies.43

Despite these initiatives, barriers to cross-border enforcement remained, and the FTC identified 

challenges that needed to be addressed for the agency to keep pace with this growing and evolving 

problem. Key among these challenges was improving information sharing and increasing the FTC’s 

cooperation with foreign counterparts, further developing Consumer Sentinel, and exploring how the 

existing legal frameworks for sharing information might be modified to facilitate cooperation in cross37 The Toronto Strategic Partnership was formed in February 2000 by the Toronto Police Service, the Ontario Ministry of 

Consumer and Commercial Relations (now the Ministry of Public and Business Service Delivery), the Competition Bureau 

of Canada, the U.S. Postal Inspection Service, and the FTC. See FTC, Accomplishments of the Toronto Strategic 

Partnerships 2000 – 2007 (Jan. 2008), https://www.ftc.gov/reports/report-accomplishments-toronto-strategic-partnershipbetween-united-states-canada-2000-2007. 38 The Centre of Operations Linked to Telemarketing Fraud (“Project COLT”) was launched in 1998 to combat 

telemarketing-related crime. Members include the FTC, Royal Canadian Mounted Police, Sureté du Québec, Service de 

Police de la Ville de Montréal, Canada Border Services Agency, the Competition Bureau of Canada, Canada Post, U.S. 

Homeland Security (U.S. Immigration and Customs Enforcement and the U.S. Secret Service), the U.S. Postal Inspection 

Service, and the Federal Bureau of Investigation. The current incarnation of Project COLT is known as the Québec Strategic 

Partnership.

39 See Appendix B for a further discussion of the FTC’s efforts to expand Sentinel and consumer complaint reporting. 40 See Prepared Statement of the Federal Trade Commission on “Cross-Border Fraud” before the Subcommittee on 

Investigations of the Committee on Governmental Affairs, U.S. Senate, Washington, D.C. (June 15, 2001), 

https://www.ftc.gov/sites/default/files/documents/public_statements/prepared-statement-federal-trade-commission-crossborder-fraud/cbftest.pdf. 41 See Press Release, FTC, Arizona Loan Broker, Defendant in FTC Case Against Canadian Loan Scheme, Settles Charges

(Apr. 17, 1997), https://www.ftc.gov/news-events/news/press-releases/1997/04/arizona-loan-broker-defendant-ftc-caseagainst-canadian-loan-scheme-settles-charges. 42 See FTC, International Cooperation Agreements. https://www.ftc.gov/policy/international/international-cooperationagreements (last accessed Sept. 28, 2023). 43 A list of current Sentinel members is available at FTC, Consumer Sentinel Network Members, 

https://www.ftc.gov/enforcement/consumer-sentinel-network/members (last accessed Sept. 28, 2023).
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 11

border cases. Thus in 2005 the FTC submitted a report to Congress that proposed amendments to the 

FTC Act (15 U.S.C. §§ 41, et seq.).44

In December 2006, to provide more timely and effective international consumer protection, Congress 

passed the U.S. SAFE WEB Act.45 Through the Act, Congress provided the FTC with enhanced law 

enforcement tools, including in the areas of (1) information sharing, (2) investigative assistance, (3) 

jurisdictional authority, (4) confidentiality, and (5) enforcement relationships. As detailed in this report, 

these tools have allowed the FTC to better combat cross-border fraud, and to otherwise protect 

consumers from misconduct in an increasingly global and digital economy. Notably, the U.S. SAFE 

WEB Act authorizes the FTC to:

• Share compelled and confidential information with foreign law enforcement agencies in 

appropriate consumer protection matters.46

• Provide investigative assistance in consumer protection matters to foreign law enforcement 

agencies.47

• Protect certain material obtained from foreign sources against public disclosure.48

Importantly, the Act also confirms that the FTC Act’s prohibition against “unfair or deceptive acts or 

practices” includes certain acts or practices involving “foreign commerce”49 and supports other 

international cooperation, including through MOUs and staff exchanges.50

Since 2006, Congress has twice extended the SAFE WEB Act, in 2012 and 2020, and the FTC has 

reported on the Act’s use and effectiveness. The FTC submitted a report to Congress on the first three 

years of SAFE WEB in December 2009.51 In October 2011, all five FTC Commissioners urged 

Congress to remove the seven-year sunset provision.52 In June 2012, the FTC testified in support of 

44 The U.S. SAFE WEB Act: Protecting Consumers from Spam, Spyware, and Fraud, A Legislative Recommendation to 

Congress (June 2005) (“2005 SAFE WEB Act Proposal”), https://www.ftc.gov/sites/default/files/documents/reports/us-safeweb-act-protecting-consumers-spam-spyware-and-fraud-legislative-recommendation-congress/ussafeweb.pdf. 45 Pub. L. No. 109-455, 120 Stat. 3372 (2006) (codified in scattered sections of 15 U.S.C. and 12 U.S.C. § 3412(e)), available 

at http://uscode.house.gov/statutes/pl/109/455.pdf. 46 Sections 4(a) and 6(a) of the SAFE WEB Act codified at Sections 6(f) and 21(b)(6) of the FTC Act, 15 U.S.C. §§ 46(f) and 

57b-2(b)(6). 47 Section 4(b) of the SAFE WEB Act codified at Section 6(j) of the FTC Act, 15 U.S.C. §46(j). 48 Section 6(b) of the SAFE WEB Act codified at Section 21(f) of the FTC Act, 15 U.S.C. § 57b-2(f). 49 Section 3 of the SAFE WEB Act codified at Section 5(a)(4) of the FTC Act, 15 U.S.C. § 45(a)(4). 50 Section 9 of the SAFE WEB Act codified at Section 25A of the FTC Act, 15 U.S.C. § 57c-1. 51 The U.S. SAFE WEB Act: The First Three Years. A Report to Congress (Dec. 2009), https://www.ftc.gov/reports/us-safeweb-act-first-three-years-federal-trade-commission-report-congress. 52 Commission Letter to the Honorable John D. Rockefeller IV, Kay Bailey Hutchinson, Mark Pryor, and Patrick J. Toomey, 

United States Senate Committee on Commerce, Science and Transportation (Oct. 3, 2011) and Commission Letter to the 

Honorable Fred Upton, Henry Waxman, Mary Bono Mack, and G.K. Butterfield, U.S. House of Representatives Committee 

on Energy and Commerce (Oct. 3, 2011), https://www.ftc.gov/legal-library/browse/cases-proceedings/publicstatements/repeal-sunset-provision-us-safe-web-act-2006).
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 12

renewing the Act, set to expire in December 2013; 53 Congress renewed the Act in 2012 for an additional 

seven years.54 In October 2019, all five FTC Commissioners again urged Congress to reauthorize the 

Act.55 In 2020, Congress renewed SAFE WEB for an additional seven years.56 SAFE WEB is currently 

set to expire on September 30, 2027.57

B.Cross-Border Enforcement Cases

SAFE WEB affirmed the FTC’s authority to pursue harms that cause reasonably foreseeable injury or 

involve material conduct here in the U.S.58 As detailed in Appendix C, the FTC has initiated at least 145

enforcement actions with a public cross-border component since Congress passed SAFE WEB. These 

cases, which in many instances involve some aspect of cross-border cooperation, constitute some of the 

FTC’s most important work since the FTC last reported to Congress on SAFE WEB.

SAFE WEB affirmed the FTC’s ability to act upon unfair and deceptive practices involving foreign 

commerce that have sufficient relation to the U.S., and the FTC has vigorously pursued this mandate.59

The FTC has conducted more than 450 investigations with international components, such as foreign 

targets, evidence, or assets. Many of these investigations involved cross-border complaints. 

The examples below highlight how the FTC has acted upon cross-border complaints60 and the 

importance of having clear legislative authority to protect the public both within the U.S. and abroad, by 

pursuing matters with cross-border components. 

In re Sanctuary Belize

SAFE WEB’s clear grant of extraterritorial authority allowed the FTC to stop one of the largest overseas 

real estate investments scams targeting U.S. consumers and ultimately obtain funds for consumer redress 

that it might not have been able to do otherwise. In 2018, at the FTC’s request, a federal district court in 

Maryland issued an order temporarily shutting down the scheme, known by several names, including 

“Sanctuary Belize,” which took in more than $100 million marketing lots in what supposedly would 

53 July 2012 Prepared Statement of Hugh Stevenson, https://www.ftc.gov/legal-library/browse/prepared-statement-federaltrade-commission-reauthorizing-us-safe-web-act-2006. 54 Public L. No. 112-203, 126 Stat. 1484 (2012), available at https://www.congress.gov/112/plaws/publ203/PLAW112publ203.pdf. 55 Letter of the Federal Trade Commission to the U.S. House of Representatives, Subcommittee on Consumer Protection and 

Commerce on the U.S. SAFE WEB Act (Oct. 25, 2019), https://www.ftc.gov/legal-library/browse/cases-proceedings/publicstatements/letter-federal-trade-commission-us-house-representatives-subcommittee-consumer-protection-commerce. 56 Public L. No. 116-173, 134 Stat. 837 (2020) (codified in part at 15 U.S.C. § 44), available at 

https://www.congress.gov/116/plaws/publ173/PLAW-116publ173.pdf. 57 Id. 58 Section 3 of the SAFE WEB Act codified at Section 5(a)(4) of the FTC Act, 15 U.S.C. § 45(a)(4) (defining the term 

“unfair or deceptive acts or practices” to include those that “(i) cause or are likely to cause reasonably foreseeable injury 

within the United States; or (ii) involve material conduct occurring within the United States”).

59 Id. 60 Additional information about how the FTC uses and acts on complaints can be found in Appendix B.
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 13

become a luxury development in Central America.61 The FTC obtained a judgment for over $100 

million and settled with several of the defendants, including Belize’s Atlantic International Bank 

Limited, which FTC alleged assisted various entities in deceiving U.S. consumers.62 In August 2023, the 

FTC began the first phase of its redress efforts, sending refunds totaling approximately $10 million to 

1,198 defrauded investors.63 

MOBE Ltd.

SAFE WEB’s extraterritorial authority and consumer complaints also helped the FTC shut down an 

international operation that targeted U.S. consumers, including service members and veterans, through a 

deceptive internet business coaching scheme called “My Online Business Education” – MOBE.64

Relying in part on over 150 consumer complaints, the Commission sued MOBE in 2018.65 The FTC 

alleged that the international operation, which was run by entities and individuals in Malaysia, Australia, 

Canada, and the U.K., targeted U.S. consumers through online ads, social media, direct mailers, and live 

events held throughout the country, and falsely claimed that its program would enable people to start 

their own online businesses and earn substantial income quickly and easily. In April 2022, the 

Commission returned over $23 million to victims who invested in the program.66

On Point Global LLC

The FTC’s SAFE WEB authority and consumer complaints have also helped the FTC prevail on law 

enforcement actions in court. In February 2020, the FTC sued five individuals and more than 50 of their 

61 Ex Parte Temporary Restraining Order with Asset Freeze, Writs Ne Exeat, Appointment of Temporary Receiver, and Other 

Equitable Relief, and Order to Show Cause Why a Preliminary Injunction Should Not Issue, In re Sanctuary Belize 

Litigation, No. 1:18-cv-03309-PJM (D. Md., Oct. 31, 2018), ECF No. 13, available at 

https://www.ftc.gov/system/files/documents/cases/ecological_fox_tro.pdf. See also Press Release, FTC, At FTC’s Request, 

Court Halts Massive “Sanctuary Belize” Real Estate Investment Scam, https://www.ftc.gov/news-events/news/pressreleases/2018/11/ftcs-request-court-halts-massive-sanctuary-belize-real-estate-investment-scam. 62 See Press Release, FTC, Belizean Bank to Pay $23 Million and Cease Operations to Settle FTC Charges It Provided 

Substantial Assistance to the Sanctuary Belize Real Estate Scam (Sept. 24, 2019), https://www.ftc.gov/newsevents/news/press-releases/2019/09/belizean-bank-pay-23-million-cease-operations-settle-ftc-charges-it-providedsubstantial-assistance. 63 See Press Release, FTC, FTC Sending Refunds to Consumers who Invested in Deceptive Sanctuary Belize Real Estate 

Development Scheme Operated by Repeat Offender Andris Pukke, (Aug. 16, 2023), https://www.ftc.gov/newsevents/news/press-releases/2023/08/ftc-sending-refunds-consumers-who-invested-deceptive-sanctuary-belize-real-estatedevelopment-scheme?utm_source=govdelivery. 64 FTC v. MOBE Ltd., No. 6:18-cv-862-ORL-37DCI, (M.D. Fla. June 4, 2018). See also Press Release, FTC, FTC Action 

Halts MOBE, a Massive Internet Business Coaching Scheme (June 11, 2018), https://www.ftc.gov/news-events/news/pressreleases/2018/06/ftc-action-halts-mobe-massive-internet-business-coaching-scheme. 65 Plaintiff’s Ex Parte Motion and Memorandum of Law in Support of a Temporary Restraining Order and Order to Show 

Cause why a Preliminary Injunction Should not Issue at 18, FTC v. MOBE Ltd., No. 6:18-cv-862-ORL-37DCI, (M.D. Fla. 

June 4, 2018), ECF No. 3, available at https://www.ftc.gov/system/files/documents/cases/mobe_motionmemo_for_tro_not_file_stamped.pdf. 66 See Press Release, FTC, Federal Trade Commission Returns More Than $23 Million To Consumers Deceived by Online 

Business Coaching Scheme MOB (Apr. 5, 2022), https://www.ftc.gov/news-events/news/press-releases/2022/04/federaltrade-commission-returns-more-23-million-consumers-deceived-online-business-coaching-scheme. 
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FEDERAL TRADE COMMISSION • FTC.GOV 14

companies for operating hundreds of fake government assistance websites.67 The defendants included a 

call center in Costa Rica (which handled calls with U.S. consumers) and a web development office in 

Uruguay (which created content targeting consumers). The Court found, based in part on consumer 

complaints, that the FTC was likely to prevail on the merits of its cases and issued a preliminary 

injunction that, among other things, stopped the defendants from misrepresenting their services.68 After 

winning at trial, the FTC made $102 million in refunds available to consumers who were harmed by the 

scheme.69

Next-Gen, Inc. 

Through the use of SAFE WEB and consumer complaints, the FTC has also been able to seek effective 

relief for consumers in the U.S. and abroad simultaneously. In February 2018, in FTC v. Next-Gen, Inc., 

the FTC and the State of Missouri charged two men and their sweepstakes operation with scamming tens 

of millions of dollars from consumers throughout the U.S. and other countries, including Canada, the 

U.K., France, and Germany.70 The FTC and Missouri alleged that the defendants, operating from the 

U.S. under dozens of different names, sent tens of millions of personalized mailers falsely indicating that 

the recipient had won or was likely to win a substantial cash prize in exchange for a fee ranging from $9 

to $139.99, resulting in losses of more than $110 million. Consumer complaints showed the extent to 

which the defendants had deceived consumers in various countries for years. The FTC settled with the 

defendants, permanently banning them from the prize promotion business,71 and sent nearly $25 million 

to consumers who were defrauded by the scheme.72 While most redress went to consumers in the U.S. 

and Canada, who received checks totaling $19,180,753, the FTC – in cooperation with several foreign 

counterparts – also sent debit cards totaling $631,322 to consumers in the U.K., and letters to consumers 

in more than 50 other countries explaining how they could claim their payments via PayPal, which 

totaled $4,696,242. 

67 FTC v. On Point Global LLC, No. 19-cv-25046 (S.D. Fla. Dec. 9, 2019). See also Press Release, FTC, Court Stops 

Sprawling Scheme That Operated Hundreds of Websites That Deceived Consumers About Government Services (Fed. 5, 

2020), https://www.ftc.gov/news-events/news/press-releases/2020/02/court-stops-sprawling-scheme-operated-hundredswebsites-deceived-consumers-about-government-services. 68 Plaintiff’s Ex Parte Motion for a Temporary Restraining Order and Memorandum in Support Thereof at 3 and Order 

Granting Motion for Preliminary Injunction, FTC v. On Point Global LLC, No. 19-cv-25046 (S.D. Fla. Dec. 9, 2019), ECF

Nos. 4 and 126, available at https://www.ftc.gov/system/files/documents/cases/on_point_tro_memorandum.pdf and

https://www.ftc.gov/system/files/documents/cases/revenue_path-on_point_global_llc_preliminary_injunction.pdf. 69 See Press Release, FTC, FTC Win at Trial Against On Point Global Makes $102 Million in Refunds Available for 

Consumers Harmed by Fake Government Website Scams (Apr. 7, 2022), https://www.ftc.gov/news-events/news/pressreleases/2022/04/ftc-win-at-trial-against-on-point-global-makes-102-million-in-refunds-for-consumers. 70 FTC v. Next-Gen, Inc., No. 4:18-CV-0128 (W.D. Mo. Feb. 20, 2018). See also Press Release, FTC, FTC Challenges 

Schemes That Target or Affect Senior Citizens (Feb. 22, 2018), https://www.ftc.gov/news-events/news/pressreleases/2018/02/ftc-challenges-schemes-target-or-affect-senior-citizens. 71 See Press Release, FTC, Operators of Sweepstakes Scam Will Forfeit $30 Million to Settle FTC Charges, 

https://www.ftc.gov/news-events/news/press-releases/2019/03/operators-sweepstakes-scam-will-forfeit-30-million-settle-ftccharges. 72 See Press Release, FTC, U.S. Federal Trade Commission Returning Almost $25 Million to Consumers Worldwide Who 

Were Defrauded by Next-Gen Sweepstakes Scheme (July 19, 2022), https://www.ftc.gov/news-events/news/pressreleases/2022/07/us-federal-trade-commission-returning-almost-25-million-consumers-worldwide-who-were-defrauded-next. 
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FEDERAL TRADE COMMISSION • FTC.GOV 15

Fashion Nova, Inc. 

Similarly, after cross-border complaints helped alert the FTC to the harmful practices of an international 

online retailer, the FTC relied on its SAFE WEB authority to enjoin the company’s practices and obtain 

refunds for its customers. In 2020, in FTC v. Fashion Nova, Inc., the FTC settled allegations that 

Fashion Nova violated the FTC’s Mail, Internet, or Telephone Order Merchandise Rule (16 C.F.R. Part 

435).73 According to the FTC, Fashion Nova marketed and sold clothing and accessories to consumers 

in the U.S. and many other countries, but failed to properly notify consumers and give them the chance 

to cancel their orders when it did not ship their merchandise in a timely manner. The FTC received 

thousands of complaints about Fashion Nova’s practices from U.S. consumers, and hundreds from 

consumers in Canada and more than fifty other countries. Pursuant to an FTC settlement, Fashion Nova 

refunded $2.26 million directly to consumers. The FTC also sent more than $6.5 million to injured 

consumers, mostly in the U.S., but also including more than $500,000 to consumers in 169 other 

countries.74 This kind of result amplifies the deterrent effect on firms contemplating similar conduct.

Best Priced Brands, LLC 

Although the FTC primarily employs SAFE WEB to protect U.S. consumers, SAFE WEB also clarifies 

and strengthens the FTC’s ability to bring actions against U.S. companies even when their actions affect 

only foreign consumers. In 2009, the FTC pursued its first action against a U.S. company doing business 

exclusively with foreign consumers. The FTC sued Balls of Kryptonite, LLC, and its owner Javian 

Karnani (all doing business as Best Priced Brands and Bite Size Deals) after learning of a series of 

cross-border complaints against the entities.75 Best Priced Brands, a California-based online electronics 

retailer, sold electronic products to consumers in the U.K., misleading them into believing that they were 

purchasing items from a U.K.-based company. Many U.K. consumers filed complaints through 

econsumer.gov noting they had been charged unexpected import duties and were told they would be 

charged high cancellation and refund fees if they attempted to return the merchandise. The FTC, 

following assistance by the U.K. Office of Fair Trading (“OFT”), filed suit in the U.S. District Court for 

the Central District of California, ultimately reaching a settlement with the defendants curbing such 

deceptive practices.76 By going after scammers in the U.S. who harm consumers abroad, the FTC is able 

to protect the integrity and reputation of the U.S. market, and encourage reciprocal assistance from 

foreign enforcers. 

73 FTC v. Fashion Nova, Inc., No. 2:20-cv-3641 (C.D. Cal. Apr. 20, 2020). See also Press Release, FTC, Fashion Nova Will 

Pay $9.3 Million for Consumer Refunds To Settle FTC Charges It Violated Rules On Shipping, Refunds (Apr. 21, 2020), 

https://www.ftc.gov/news-events/news/press-releases/2020/04/fashion-nova-will-pay-93-million-consumer-refunds-settle-ftccharges-it-violated-rules-shipping. 74 See Press Release, FTC, FTC Sends More Than $6.5 Million to Consumers Harmed by Fashion Nova (Mar. 25, 2021), 

https://www.ftc.gov/news-events/news/press-releases/2021/03/ftc-sends-more-65-million-consumers-harmed-fashion-nova. 75 FTC v. Javian Karnani, No. 09-CV-5276 (C.D. Cal. July 20, 2009). See also Press Release, FTC, Court Halts U.S. Internet 

Seller Deceptively Posing as U.K. Home Electronics Site (Aug. 6, 2009), https://www.ftc.gov/news-events/news/pressreleases/2009/08/court-halts-us-internet-seller-deceptively-posing-uk-home-electronics-site. 76 See Press Release, FTC, FTC Settlement Bans Online U.S. Electronics Retailer from Deceiving Consumers with Foreign 

Website Names (June 9, 2011), https://www.ftc.gov/news-events/news/press-releases/2011/06/ftc-settlement-bans-online-uselectronics-retailer-deceiving-consumers-foreign-website-names. 
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CafePress

The ability to bring such actions is also the cornerstone of our role in enforcing the substantive 

provisions of international data transfer programs enabling trillions of dollars in cross-border commerce, 

such as the European Union (“EU”)-U.S. Data Privacy Framework (the successor to the Privacy Shield 

and Safe Harbor programs)77 and the Asia-Pacific Economic Cooperation (“APEC”) Cross-Border 

Privacy Rules System.78 In these programs, U.S. companies can voluntarily make commitments on the 

treatment of data in order to enable its transfer from various foreign countries; those commitments then 

become enforceable as a matter of U.S. law under the FTC Act, as amended by SAFE WEB. One 

example of such a case is CafePress, in which the FTC alleged that the U.S. defendant, a participant in 

the EU-U.S. Privacy Shield program, did not comply with its commitments to provide EU consumers 

with the framework commitments as to choice, security, and access.79

SAFE WEB’s explicit affirmation of the FTC’s authority to pursue matters involving foreign commerce 

has helped the FTC prevail against jurisdictional challenges in many of the matters discussed above.80

Thus, the Act constitutes a crucial component of the FTC’s ability to effectively combat cross-border 

fraud, as well as other cross-border misconduct, that harms U.S. consumers.

C.Use of SAFE WEB Cooperation Tools

SAFE WEB gave the FTC the ability to share confidential or compelled information and to help foreign 

law enforcement agencies obtain U.S.-based evidence. These powers have been key in helping the FTC 

and foreign law enforcement cooperatively investigate to stop cross border fraud. Chief among these

powers is the FTC’s ability to share compelled or confidential information with and provide 

investigatory assistance to foreign law enforcement agencies. 

As of June 30, 2023, the FTC has:

• Shared confidential or compelled information in response to 175 SAFE WEB sharing requests 

from 43 law enforcement agencies in 20 different countries. 

77 See U.S. Department of Commerce, Data Privacy Framework Program, EU-U.S. Data Privacy Framework and letter from 

Lina M. Khan, Chair of the Federal Trade Commission, Didier Reynders, Commissioner for Justice, European Commission 

(June 9, 2023), https://www.dataprivacyframework.gov/s/framework-text (last accessed Sept. 28, 2023). 78 See Cross Border Privacy Rules System, https://cbprs.org/ (last accessed Sept. 28, 2023). 79 In the Matter of Residual Pumpkin, LLC (formerly d/b/a CafePress), Nos. C-4768, C-4769 (Mar. 15, 2021), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/1923209-cafepress-matter; See also In the Matter of Flo Health, 

Inc., No. C-4747 (Jan. 13, 2021), available at https://www.ftc.gov/legal-library/browse/cases-proceedings/192-3133-flohealth-inc (alleging that Flo Health did not comply with Privacy Shield commitments to provide E.U. consumers with notice, 

choice, and accountability for onward transfers). 80 See, e.g., In re Sanctuary Belize, 482 F. Supp. 3d 373, 396 n.19 (D. Md. Aug. 28, 2020) (finding that the U.S. SAFE WEB 

Act decreed that the FTC Act and the Telemarketing Sales Rule apply extraterritorially, and that the Defendants’ deceptive 

marketing to U.S. residents “causes or is likely to cause reasonably foreseeable injury” and that “extensive material conduct 

of Defendants occurred within the United States”), available at 

https://www.ftc.gov/system/files/documents/cases/1020_memorandum_opinion.pdf. 
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• Helped its foreign enforcement partners, both civil and criminal, to obtain U.S.-based evidence 

by issuing more than 140 CIDs in 67 investigations on behalf of 21 foreign agencies from eight

countries.

Notably, the FTC has increasingly made active use of these tools. The activity described above includes 

more than 150 additional information sharing requests and more than 110 additional CIDs since 

the FTC reported to Congress on its experience using the U.S. SAFE WEB Act in 2009.81

Of critical importance, SAFE WEB cooperation often provides foreign counterparts with evidence that 

helps them to fight conduct affecting U.S. consumers.82 Such cooperation has also encouraged

reciprocal assistance from other countries, including through MOUs. Even more, SAFE WEB has 

established the FTC as a global example of effective cross-border cooperation in consumer protection 

matters83 and encouraged other countries to adopt similar domestic legislation, to the benefit of the U.S. 

For example, in 2010, Canada passed anti-spam legislation with mutual assistance provisions modeled 

on the SAFE WEB Act.84 The FTC has also been able to grow our relationships with other agencies, 

helping to advance the mutual cause of protecting consumers through more than a decade of staff 

exchanges. 

81 The work of law enforcement is often non-public and law enforcement agencies, both foreign and domestic, do not 

necessarily report back to the FTC on the results of FTC cooperation, including whether a foreign agency has engaged in an 

enforcement action. Examples of important public enforcement results obtained by foreign law enforcement and of which the 

FTC is aware are nevertheless provided in this report.

82 Many of the cases tackled by the Canadian regional partnerships, for example, have involved Canada-based telemarketers 

targeting U.S. victims. Other cases pursued by foreign enforcers have involved both U.S. and foreign victims.

83 See generally Organisation for Economic Cooperation and Development, Implementation toolkit on legislative actions for 

consumer protection enforcement co-operation (June 17, 2021), https://www.oecd.org/digital/implementation-toolkit-onlegislative-actions-for-consumer-protection-enforcement-co-operation-eddcdc57-en.htm. The toolkit is a “practical resource 

for consumer protection enforcement agencies that do not currently have the domestic legal authority needed for enforcement 

co-operation to make the case for obtaining relevant legislative tools.” Id. at 2. 84 An Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage 

reliance on electronic means of carrying out commercial activities, and to amend the Canadian Radio-television and 

Telecommunications Commission Act, the Competition Act, the Personal Information Protection and Electronic Documents 

Act and the Telecommunications Act (S.C. 2010, c. 23), available at https://laws-lois.justice.gc.ca/eng/acts/E-1.6/index.html). 

See also https://fightspam-combattrelepourriel.ised-isde.canada.ca/site/canada-anti-spam-legislation/en. Remarking on the 

legislation at the FTC’s 2019 International Hearings on Competition and Consumer Protection in the 21st Century, CBC 

Commissioner Matthew Boswell commented that “[O]ur legal framework and ability to assist and share information with our 

foreign counterparts has improved significantly with the enactment of Canada's Anti-Spam Law, or ‘C-A-S-L.’ ‘C-A-S-L’ 

recently brought into force new express provisions allowing the Bureau to use our investigative powers under the 

Competition Act or Criminal Code to assist foreign partners, without us having to be conducting our own investigation. It 

grants these powers with the provision that information will only be used for that investigation or proceeding and will be kept 

confidential, similar to provisions in the U.S. Safe Web Act.”
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1. Sharing of Confidential and Compelled Information with Foreign 

Agencies

SAFE WEB authorizes the FTC to share information with foreign law enforcement agencies.85

Importantly, SAFE WEB permits the FTC to share certain confidential and compelled information in its 

consumer protection investigations, upon certification by the foreign agency that the material will be 

maintained in confidence and used only to investigate or engage in enforcement proceedings related to 

“possible violations of . . . foreign laws prohibiting fraudulent or deceptive commercial practice, or other 

practices substantially similar to practices prohibited by any law administered by the Commission.”86

This standard permits the FTC to share with criminal as well as civil authorities, so long as the practices 

in question are “substantially similar.” Prior to Congress passing the Act, the FTC could only share this 

information with U.S. enforcers. FTC procedures for handling requests from foreign law enforcement 

agencies are implemented in Commission Rule 4.11(j).87

The FTC has responded to 175 SAFE WEB information sharing requests from 43 law enforcement 

agencies in 20 different countries. A list of the agencies with which the FTC has shared non-public 

information pursuant to the Act since 2012 is set forth in Figure 4. This has included sharing compelled 

and confidential information related to foreign matters involving, for example, robocalls, text message 

spam, false advertising, data breaches, and sweepstake scams. Without SAFE WEB, sharing key 

enforcement information with these important partners would have been barred under the FTC Act. 

Figure 4: SAFE WEB Information Sharing Agencies

Name of Agency Country

Australian Competition and Consumer Commission Australia

Australian Communications and Media Authority Australia

Office of the Australian Information Commissioner Australia

Federal Ministry for Social Affairs, Health Care, and Consumer 

Protection

Austria 

BG Directorate-General for Economic Inspection Belgium

Bulgarian National Bank Bulgaria

Alberta Justice Canada

85 SAFE WEB Act Sections 4(a) and 6(a) codified in Sections 6(f) and 21(b)(6) of the FTC Act, 15 U.S.C. §§ 46(f) and 57b2(b)(6)). “Foreign Law Enforcement Agency” means “any agency or judicial authority of a foreign government, including a 

foreign state, or a multinational organization constituted by and comprised of foreign states, that is vested with law 

enforcement or investigative authority in civil, criminal, or administrative matters” and “any multinational organization, to 

the extent that it is acting on behalf of” any such agency or judicial authority. SAFE WEB Act Section 2 codified in Section 4 

of the FTC Act, 15 U.S.C. § 44. 86 Id. Antitrust laws enforced by the FTC are not covered by the provisions. 15 U.S.C. §§ 46(f)(2) and 57b-2(b)(6). The Act 

also does not authorize the FTC to share information with agencies from countries that the Secretary of State has determined 

repeatedly support international terrorism. 15 U.S.C. § 57b-2(b)(6)(D). This prohibition also applies to agencies submitting 

requests for investigative assistance. 15 U.S.C. § 46(j)(7). 87 16 C.F.R. §4.11(j). 
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British Columbia Consumer Protection Canada

Competition Bureau Canada

Canadian Radio-television and Telecommunication Commission Canada

Edmonton Police Service Canada

Health Canada Canada

Kahnawake Mohawk Peacekeepers Canada

Ministry of the Attorney General (Ontario, Canada) Canada

Ontario Provincial Police Canada

Office of the Privacy Commissioner of Canada Canada

Royal Canadian Mounted Police Canada

Service Alberta Canada

Toronto Police Service Canada

York Police Canada

Superintendency of Industry and Commerce Colombia

Ministry of Commerce Cyprus

Office of the Communication Authority Hong Kong

Competition and Consumer Protection Commission Ireland

Israel Consumer Protection and Fair Trade Authority Israel

Consumer Affairs Agency Japan

Korea Communications Commission Korea

Luxembourg National Data Protection Commission Luxembourg

Netherlands Independent Post and Telecommunications Authority Netherlands

New Zealand Department of Internal Affairs New Zealand

National Privacy Commission Philippines

Singapore Police Singapore

State Secretariat for Economic Affairs Switzerland

City of London Police U.K.

Competition and Markets Authority U.K.

Financial Conduct Authority U.K.

Information Commissioner's Office U.K.

UK Insolvency Service U.K.

Office of Fair Trading U.K.

Serious Organised Crime Agency U.K.

Staffordshire County Council U.K.

Trading Scams Team U.K.

Security Service Ukraine Ukraine
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Such information sharing activities with foreign law enforcement agencies have supported the FTC’s 

enforcement efforts in many cases, including the following:

Designer Brand Outlet 

Actions taken by the Australian Competition and Consumer Commission (“ACCC”) against Designer 

Brand Outlet, with assistance from the FTC and the U.K.’s OFT, is an early example of how sharing 

information benefits consumer protection enforcement. Leading up to August 2008, consumers from 

around the world had complained that www.designerbrandoutlet.com, which purported to sell genuine, 

designer-label goods, had not delivered ordered goods, had delivered counterfeit goods, and had failed 

to provide refunds after consumers returned non-conforming goods. The FTC, having identified a series 

of complaints in econsumer.gov, notified the ACCC and, with the U.K.’s OFT, assisted the ACCC in 

investigating the scam. In late August 2008, having been contacted by the ACCC about the complaints, 

the Australian domain registrar NetRegistry Pty Ltd quickly disabled the domain name. In early 

September 2008, the ACCC filed proceedings against www.designerbrandoutlet.com and related 

individuals operating from China for false and misleading representations, obtaining an ex parte

injunction freezing their assets and suspending their operations.88 An Australian court found in favor of 

the ACCC in December 2008 and ordered compensation hearings (to provide redress to individual 

consumers).89

Ashley Madison

In 2016, the operators of the Toronto-based AshleyMadison.com dating site agreed to settle FTC 

charges that they deceived consumers and failed to protect 36 million users’ account and profile 

information in relation to a massive July 2015 data breach of their network.90 The website had users 

from over 46 countries. The FTC relied on key provisions of the SAFE WEB Act to share information 

with the Office of the Privacy Commissioner of Canada (“OPC”) and the Office of the Australian 

Information Commissioner (“OAIC”), which reached their own settlements with the company and also 

contributed to the FTC’s investigation. In 2017, the three agencies received an award for their crossborder investigation of the data breach from the Chair of what is now known as the Global Privacy 

88 See Press Release, Australian Competition and Consumer Commission, ‘Designer Brand Outlet’ website suspended (Sept. 

9, 2008), https://www.accc.gov.au/media-release/designer-brand-outlet-website-suspended and Press Release, Australian 

Competition and Consumer Commission, Were you misled by Designer Brand Outlet? (Sept. 19, 2008) 

https://www.accc.gov.au/media-release/were-you-misled-by-designer-brand-outlet. 89 See Press Release, Australian Competition and Consumer Commission, Court declares operators of Designer Brand Outlet 

website misled consumers (Dec. 15, 2008), https://www.accc.gov.au/media-release/court-declares-operators-of-designerbrand-outlet-website-misled-consumers and Press Release, Australian Competition and Consumer Commission, Refunds for 

some consumers who bought from Designer Brand Outlet (Apr. 28, 2009), https://www.accc.gov.au/media-release/refundsfor-some-consumers-who-bought-from-designer-brand-outlet. 90 FTC v. Ruby Corp., No. 1:16-cv-02438 (D.D.C. Dec. 14, 2016). See Press Release, FTC, Operators of AshleyMadison.com 

Settle FTC, State Charges Resulting From 2015 Data Breach that Exposed 36 Million Users’ Profile Information (Dec. 14, 

2016), https://www.ftc.gov/news-events/news/press-releases/2016/12/operators-ashleymadisoncom-settle-ftc-state-chargesresulting-2015-data-breach-exposed-36-million.
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Assembly, who called the agencies’ work “a model on how to achieve cross-border cooperation in 

privacy enforcement.”91

Foreign Money Offer Scams/MoneyGram/Western Union 

Cross-border complaints, and a cooperative enforcement approach fostered by the U.S. SAFE WEB Act, 

helped the FTC work with foreign law enforcement agencies to stop a large criminal network. In 2013 

and 2014, the FTC shared consumer complaints regarding fraudulent money transfers to Western Union 

and MoneyGram locations in Spain in connection with a Nigerian email scam. The scam, which 

involved spamming consumers with emails and persuading them to pay large sums of money for future 

financial rewards that never materialized, resulted in consumers, mostly in the U.S. and Canada, sending 

over $15 million to transfer booths across Spain in 2011 and 2012. Ultimately, the FTC, U.S. criminal 

authorities, and the Canadian Anti-Fraud Centre shared consumer complaints with the Spanish National 

Police via Europol, and in July 2014 the Spanish National Police arrested 84 Western Union agents 

involved in the scam, 80% of whom were Nigerian citizens. In 2017, when the FTC sued Western Union 

for failing to put in place effective anti-fraud policies and procedures, it cited this as one of several 

examples of Western Union’s failing to act promptly against problem agents.92 Western Union 

ultimately forfeited $586 million to the FTC and the Justice Department, and the FTC distributed 

approximately $300 million to redress victims.93

FTC v. Jesse Willms

In 2011, the FTC used SAFE WEB to help stop a multi-million dollar cross-border scam that injured 

more than four million U.S. consumers. In FTC v. Jesse Willms, the FTC sued the operators of an online 

operation that the FTC alleged lured consumers into “free” or “risk free” offers for various products that 

supposedly required only small shipping and handling fees.94 The scam’s operators, having obtained 

consumers’ credit or debit card account numbers, then charged consumers substantial monthly recurring 

fees and often failed to provide refunds despite a money-back guarantee. The FTC alleged the 

defendants, mostly located in Canada, took in more than $467 million from consumers in the U.S., 

Canada, the U.K., Australia, and New Zealand, with most of the injured consumers residing in the U.S.

91 See Press Release, FTC, FTC Earns Prestigious International Award for AshleyMadison.com Data Breach Investigation 

(Sept. 27, 2017), https://www.ftc.gov/news-events/news/press-releases/2017/09/ftc-earns-prestigious-international-awardashleymadisoncom-data-breach-investigation. 92 FTC v. Western Union Co., No. 1:17-cv-00110-CCC (M.D. Pa. Jan. 19, 2017). See also Press Release, FTC, Western 

Union Admits Anti-Money Laundering Violations and Settles Consumer Fraud Charges, Forfeits $586 Million in Settlement 

with FTC and Justice Department (Jan. 19, 2017), https://www.ftc.gov/news-events/news/press-releases/2017/01/westernunion-admits-anti-money-laundering-violations-settles-consumer-fraud-charges-forfeits-586. 93 See FTC, Western Union Refunds (Sept. 2023), https://www.ftc.gov/enforcement/refunds/western-union-refunds. 94 FTC v. Jesse Willms, No. 2:11-CV-00828 (W.D. Wash. May 16, 2011). See also Press Release, FTC, FTC Charges Online 

Marketers with Scamming Consumers out of Hundreds of Millions of Dollars with 'Free' Trial Offers (May 17, 2011), 

https://www.ftc.gov/news-events/news/press-releases/2011/05/ftc-charges-online-marketers-scamming-consumers-outhundreds-millions-dollars-free-trial-offers.
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The FTC worked closely with Canadian law enforcement, including the Alberta Partnership Against 

Cross Border Fraud,95 in investigating this international scheme.96 The FTC used SAFE WEB’s 

information sharing provisions to share information with Canadian law enforcers, including the 

Competition Bureau Canada and the Royal Canadian Mounted Police (“RCMP”), which in turn 

provided investigative assistance to the FTC. The case resulted in the entry of U.S. court injunctions and 

monetary judgments, including a $359 million judgment and permanent ban against twelve defendants.97

In re Cambridge Analytica, LLC

The FTC used SAFE WEB to share information with the U.K.’s Information Commissioner's Office 

(“ICO”) concerning Cambridge Analytica. Both agencies were investigating Cambridge Analytica for 

having harvested personal information from millions of Facebook users. In October 2018, the ICO fined 

Facebook £500,000.98 In July 2019, the FTC sued Cambridge Analytica and filed settlements with the 

company’s former CEO and an app developer. The ICO's Deputy Commissioner called the use of these 

information-sharing powers a “huge positive” in cross-border case cooperation.99

Next-Gen, Inc. 

The FTC has also used its SAFE WEB information sharing authority to help redress injured consumers. 

In 2022, in FTC v. Next-Gen (see Section III, supra), the FTC shared information from its files with 

foreign agencies to help facilitate redress to consumers in those countries. The FTC also worked closely 

with consumer protection counterparts in 18 countries to coordinate messaging so that victims would be 

more likely to act upon the FTC’s information about claiming redress funds. 

95 See Memorandum of Understanding on the Establishment of a Joint Venture Between Alberta Government Services, 

Canada’s Competition Bureau, United States Federal Trade Commission’s Bureau of Consumer Protection, Royal Canadian 

Mounted Police, Calgary Police Service, Edmonton Police Service, and United States Postal Inspection Service on the 

Enforcement of Deceptive Marketing Practices Laws (Sept. 26, 2003), 

https://www.ftc.gov/system/files/attachments/international-competition-consumer-protection-cooperationagreements/alberta_mou.pdf. 96 See Press Release, FTC, FTC Halts Deceptive Practices of Marketer Who Collected $359 Million Using Bogus ‘Free’ Trial 

Offers (Feb. 23, 2012), https://www.ftc.gov/news-events/news/press-releases/2012/02/ftc-halts-deceptive-practices-marketerwho-collected-359-million-using-bogus-free-trial-offers. 97 See FTC, Willms, Jesse, et al. (Mar. 6, 2012), https://www.ftc.gov/legal-library/browse/cases-proceedings/102-3012-

willms-jesse-et-al. 98 See Information Commissioner’s Office, Investigation into the use of data analytics in political campaigns, A report to 

parliament (Nov. 6, 2018) at 38, https://ico.org.uk/media/action-weve-taken/2260271/investigation-into-the-use-of-dataanalytics-in-political-campaigns-final-20181105.pdf. 99 FTC Hearings on Competition and Consumer Protection in the 21st Century, Transcript from March 25, 2019 at 110, 

https://www.ftc.gov/system/files/documents/public_events/1454018/ftc_hearings_session_11_transcript_day_1_3-25-

19_0.pdf. 
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First Consumers

In 2014, in FTC v. First Consumers, LLC, the FTC moved to shut down a multi-million-dollar 

telemarketing fraud that targeted seniors across the U.S.100 The defendants, through a network of U.S. 

and Canadian entities, used a telemarketing boiler room in Canada to cold-call seniors. The defendants, 

impersonating government and bank officials, enticed consumers to disclose their confidential bank 

account information and then used that information to create checks drawn on consumers’ bank 

accounts. Those funds were deposited into accounts in the U.S. and then transferred to accounts 

controlled by the Canadian defendants. The FTC shared information with and received valuable help 

throughout the case from the RCMP, which helped serve process on Canada-based defendants. This 

matter resulted in the ringleader of the fraud being permanently banned from all telemarketing activities 

and a judgment of $10.7 million.101

As these examples demonstrate, SAFE WEB has been critical to stopping scams and other practices that 

have harmed consumers around the world, but especially in the U.S. This includes stopping scams that 

have caused significant financial injury. SAFE WEB has also provided for more effective parallel 

investigations and helped the FTC to provide redress to injured consumers. Finally, sharing information 

with our foreign law enforcement partners makes them more willing and able to share information with 

us. 

2. Investigative Assistance to Foreign Law Enforcement Agencies

SAFE WEB also authorizes the FTC to provide investigative assistance to foreign law enforcement 

agencies.102 The Act authorizes the Commission to “conduct such investigation as the Commission 

deems necessary to collect [pertinent] information and evidence. . . using all investigative powers 

authorized by [the FTC Act]” if certain criteria are met.103 SAFE WEB also authorizes the FTC to 

initiate proceedings in federal district court pursuant to 28 U.S.C. § 1782 on behalf of foreign agencies 

to obtain testimony, documents, or things for use in foreign proceedings.104

Congress set forth certain requirements when the FTC provides investigative assistance to foreign law 

enforcement agencies. First, in a written request, the foreign agency must state that it is investigating or 

engaging in enforcement proceedings against “possible violations of laws prohibiting fraudulent or 

deceptive commercial practice, or other practices substantially similar to practices prohibited by any 

provision of the laws administered by the Commission (other than federal antitrust laws) . . .” In 

addition, in deciding whether to provide such assistance, the Commission must consider all relevant 

100 FTC v. First Consumers, LLC, No. 14-CV-1608 (E.D. Pa. March 18, 2014). See also Press Release, FTC, FTC Stops Mass 

Telemarketing Scam That Defrauded U.S. Seniors and Others Out of Millions of Dollars (Mar. 31, 2014), 

https://www.ftc.gov/news-events/news/press-releases/2014/03/ftc-stops-mass-telemarketing-scam-defrauded-us-seniorsothers-out-millions-dollars. 101 See Press Release, FTC, Court Orders Ringleader of Scam Targeting Seniors Banned From Telemarketing (Mar. 12, 

2015), https://www.ftc.gov/news-events/news/press-releases/2015/03/court-orders-ringleader-scam-targeting-seniors-bannedtelemarketing. 102 Section 4(b) of the SAFE WEB Act codified in Section 6(f) of the FTC Act, 15 U.S.C. §46(j). 103 15 U.S.C. §46(j)(1)-(3). 104 15 U.S.C. §46(j)(2)(B).
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factors, including (A) whether the agency has agreed to or will provide reciprocal assistance, (B) 

whether compliance would prejudice the public interest of the U.S., and (C) whether the requesting 

agency’s investigation or proceeding “concerns acts or practices that cause or as likely to cause injury to 

a significant number of persons.”105

The FTC has provided investigatory assistance by issuing more than 140 CIDs in 67 investigations on 

behalf of 21 foreign agencies from eight countries. All of the CIDs were issued pursuant to general or 

special resolutions approved by the FTC’s Commissioners. A list of the agencies to which the FTC has 

provided investigatory assistance pursuant to SAFE WEB is set forth in Figure 5. 

Figure 5: SAFE WEB Investigatory Assistance Agencies

Name of Agency Country

Australian Competition and Consumer Commission Australia

Australian Communications and Media Authority Australia

Directorate-General for Economic Inspection Belgium 

Edmonton Police Service Canada

Competition Bureau Canada

Canadian Radio-television and Telecommunication Commission Canada

Health Canada Canada

Royal Canadian Mounted Police Canada

Toronto Police Service Canada

York Police Canada

Office of the Communication Authority Hong Kong

Consumer Affairs Agency Japan

Netherlands Independent Post and Telecommunications Authority Netherlands

New Zealand Department of Internal Affairs New Zealand

National Privacy Commission Philippines

State Secretariate for Economic Affairs Switzerland

City of London Police U.K.

Competition and Markets Authority U.K.

Information Commissioner’s Office U.K.

Office of Fair Trading U.K.

Staffordshire County Council U.K.

The nature of these requests has varied. For example, in some instances, the FTC has issued compulsory 

process to domain registrars in connection with investigations into spam, fake reviews, phishing 

105 15 U.S.C. §46(j)(3).
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schemes, or the sale of health and weight-loss supplements. In other instances, it has issued compulsory 

process to telecommunication companies or VoIP providers in connection with matters involving 

robocalls or other telemarketing matters, including a telemarketing sweepstake scam affecting U.S. 

consumers. The FTC has also issued compulsory process for subscriber information in relation to banks 

or payment processors in connection with money-laundering and multi-level marketing schemes. In each 

of these requests, the FTC carefully weighed the factors outlined in the Act and shared the information 

with the foreign agencies pursuant to the Act’s information sharing provisions. In many instances, the 

FTC’s SAFE WEB assistance to foreign law enforcement agencies has helped those agencies to take 

action against foreign-based fraudsters victimizing U.S. consumers.

Some examples of how the FTC has used SAFE WEB’s investigative assistance authority to issue 

compulsory process are highlighted below. These examples supplement those the FTC reported to 

Congress in 2009.106

• In 2014, the FTC provided SAFE WEB investigative assistance to assist the RCMP in its 

investigation of Banners Brokers, a massive online pyramid scheme based in Canada that 

targeted consumers in the U.S., Canada, and around the world. Ultimately, the Toronto Police 

(working with the RCMP) arrested two of Banners Brokers’ three principals and charged them 

criminally for their participation in the $93 million scheme.107

• In September 2018, the FTC used its SAFE WEB authority to issue six CIDs to U.S. entities 

associated with the secondary-ticketing platform viagogo, based in Switzerland. Viagogo U.K. 

(and its Swiss parent) were the subject of an enforcement action brought by the U.K.’s 

Competition and Markets Authority (“CMA”) for violating various consumer laws through its 

advertising and pricing representations.108 The company produced information to the FTC, 

which it shared with the CMA. Before the FTC moved to compel the production of other, 

responsive information, the CMA secured a court order against viagogo by consent in November 

2018, and the FTC withdrew its CIDs.109

In addition, when the FTC reported to Congress on SAFE WEB in 2009, it had not yet had the 

opportunity to use SAFE WEB to initiate proceedings on behalf of foreign agencies pursuant to 28 

U.S.C. § 1782. That changed in 2014, when the FTC successfully obtained an order for documents and 

oral testimony from Aegis Mobile, LLC (“Aegis”), a U.S. corporation, for use by Canada’s Competition 

106 2009 SAFE WEB Report at 12-14. 107 Kendra Mangione, Canadians Arrested in US$93 Million Pyramid Scheme, CTV News (Dec 9., 2015, 10:45am), 

https://www.ctvnews.ca/canada/canadians-arrested-in-us-93m-pyramid-scheme-1.2693136?cache=%3FclipId%3D64268. In 

2017, both men pled guilty to operating a pyramid scheme under the Canada Competition Act. 

108 See FTC, In the Matter of September 13, 2018 Civil Investigative Demands Issued to viagogo, Inc.; viagogo 

Entertainment Inc.; Pugnacious Endeavors, Inc.; Grover Street, Inc.; and Grover Street Holdings, Inc. (Nov. 29, 2018), 

https://www.ftc.gov/legal-library/browse/cases-proceedings/petitions-quash/matter-september-13-2018-civil-investigativedemands-issued-viagogo-inc-viagogo-entertainment-inc-0 and Press Release, United Kingdom, CMA launches court action 

against viagogo (Aug. 31, 2018), https://www.gov.uk/government/news/cma-launches-court-action-against-viagogo. 109 See Competition and Markets Authority v. viagogo, No. FS-2018-000011, Order, (Ch, Nov 27, 2018) (U.K.)., available at

https://assets.publishing.service.gov.uk/media/5bffe2afe5274a0fae2c5397/CMA_v_Viagogo_Order_27.11.pdf. 
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Bureau (“CCB”).110 The CCB requested the FTC’s assistance in obtaining evidence from Aegis for use 

in its investigation of and enforcement proceeding against various Canadian wireless companies alleged 

to have deceptively advertised certain premium cellular services. 

The FTC used SAFE WEB to obtain an order from a U.S. federal district court on behalf of the CBC.111

The order permitted the FTC to obtain oral and documentary testimony from Aegis, with the FTC 

ultimately obtaining documents and deposing two corporate representatives, and then sharing such 

information with the CCB. The CCB in turn obtained over $24 million in refunds for victims of these 

deceptive practices.112 Commissioner Matthew Boswell of the CCB, one of the FTC’s most 

longstanding international partners, has said that this assistance was “of tremendous assistance to the 

Bureau in advancing its case.”113

3. International Cooperation Agreements

The FTC’s ability to share information and offer investigation assistance to foreign law enforcement 

agencies through SAFE WEB has also resulted in reciprocal assistance and cooperation from other 

countries.

To further international cooperation, the FTC enters into international arrangements, agreements, and 

MOUs with consumer protection agencies around the world. In these arrangements and agreements, the 

FTC represents that it will endeavor to engage in enforcement cooperation and information sharing. 

These important representations rest on the cooperation the FTC can provide to agencies through the 

Act. Because many foreign law enforcement agencies require such arrangements to assist the FTC, 

SAFE WEB’s cooperation tools have also increased assistance to the FTC, to the benefit of consumers. 

Without SAFE WEB, the assistance the FTC can offer other law enforcement agencies and, as a result, 

the reciprocal assistance that the FTC receives, would be more limited. 

Based on the SAFE WEB powers, the FTC has expanded its international cooperation by entering into 

MOUs with consumer, privacy, and/or telecommunications authorities in Canada, Chile, Colombia, 

Ireland, Mexico, the Netherlands, Nigeria, Peru, the U.K., the APEC cross-border privacy rules system, 

and public authorities that are members of the Unsolicited Communications Enforcement Network

(UCENet).

114 This includes, for example, the FTC’s 2017 MOU on Consumer Fraud Enforcement 

110 See In re Application of the FTC for an Order Pursuant to 28 U.S.C. § 1782 to Obtain Information from Aegis Mobille 

LLC on Behalf of the Competition Bureau, Canada, for use by Foreign Judicial Proceedings, 2014 U.S. Dist. LEXIS 106214

(D. Md. Aug. 4, 2014), available at https://www.ftc.gov/system/files/documents/cases/aegis_2014-08-

04_corrected_decision.pdf. 111 Id. 112 See Press Release, Canada, Bell customers to receive up to $11.82 million as part of Competition Bureau agreement (May 

27, 2016), https://www.canada.ca/en/competition-bureau/news/2016/05/bell-customers-to-receive-up-to-11-82-million-aspart-of-competition-bureau-agreement.html. 113 Speech, Canada, International cooperation in competition law: views from above the 49th parallel (Mar. 25, 2019), 

https://www.canada.ca/en/competition-bureau/news/2019/03/international-cooperation-in-competition-law-views-fromabove-the-49th-parallel.html. 114 Some FTC MOUs on the other hand were undertaken before the legislation took effect or are otherwise not based on those 

powers. Copies of the FTC’s international cooperation arrangements are available at FTC, International Cooperation 

Agreements, https://www.ftc.gov/policy/international/international-cooperation-agreements (last accessed Sept. 28, 2023).
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between the FTC and the RCMP, which expanded and strengthened the agencies’ efforts to share 

information, engage in joint investigations, and combat cross-border fraud.

4. International Staff Exchanges

SAFE WEB also authorizes the FTC to participate in staff exchanges with foreign government agencies. 

SAFE WEB authorizes the FTC to employ on a temporary basis officers or employees of foreign 

government agencies. It also provides that FTC officers or employees may work on a temporary basis 

for appropriate foreign government agencies.115 This provision in the Act applies to both competition 

and consumer protection activities.

The purpose of these staff exchanges, as the FTC noted in proposing such a provision, is to “improve 

international law enforcement cooperation in cross-border matters.” As the FTC explained in proposing 

the Act in 2005, “Allowing foreign employees to work on FTC cases and investigations and have access 

to confidential material would help those employees learn about FTC investigative techniques and later 

adopt those techniques in their agency investigations. They could also provide significant help 

investigating joint cases involving evidence or witnesses located in their country.”116

Through the FTC’s International Fellows Program and SAFE WEB Interns Program, 133 foreign 

colleagues from 41 jurisdictions have come to work alongside FTC staff in the agency’s Bureaus of 

Competition, Consumer Protection, and Economics, and the Office of Policy Planning.117 These Fellows 

work with FTC attorneys, economists, investigators, and other staff, generally for three to six months, 

participating in activities such as investigations and enforcement proceedings, and gaining first-hand 

experience of how the FTC carries out its mission.118 After the program, they return to their home 

agencies, able to share what they have learned and to help improve cross-border cooperation through the 

relationships they have developed. In turn, the FTC gains insight into their home agencies’ laws, 

enforcement actions and approaches. It helps all concerned find common ground despite the inevitable 

legal and cultural differences that exist between any two agencies.

115 Section 9 of the SAFE WEB Act codified in section 25a of the FTC Act, 15 U.S.C. § 57c-1. Section 9 permits the FTC to

“retain or employ officers or employees of foreign government agencies on a temporary basis as employees of the 

Commission.” It also authorizes the FTC to “detail officers or employees of the Commission to work on a temporary basis 

for appropriate foreign government agencies.” 116 FTC, An Explanation of the Provisions of the US SAFE WEB Act, explanation-provisions-us-safe-web-act.pdf (last 

accessed Sept. 28, 2023) (provided in connection with the FTC’s 2005 SAFE WEB Act Proposal, supra note 44). This 

explanation also noted, “The types of exchanges contemplated here would not involve exchanges in highly classified or 

sensitive areas. Indeed, the FTC is often pursuing the same targets as its foreign counterparts, and the ability to develop joint 

investigations and cases while a foreign employee is detailed to the FTC would be highly beneficial. The same reasoning 

applies in the antitrust area, and therefore, we recommend that this provision cover staff exchanges on both the competition 

and consumer protection sides of the FTC’s mission.” Id. at n.66. 117 During their assignments, fellows and interns work under the direct supervision of FTC officials and do not perform 

inherently governmental functions. Since 2007, the FTC has hosted fellows and interns from Argentina, Australia, Austria, 

Barbados, Brazil, Canada, Chile, China, Columbia, Egypt, El Salvador, Ecuador, Egypt, the European Commission, France, 

the Gambia, Honduras, Hungary, India, Israel, Japan, Kazakhstan, Kenya, Lithuania, Mauritius, Mexico, Nigeria, Pakistan, 

Peru, the Philippines, Poland, Saudi Arabia, Singapore, South Africa, south Korea, Switzerland, Tanzania, Turkey, Ukraine, 

the U.K., Vietnam, and Zambia. 118 SAFE WEB interns engage in similar work, but for shorter terms. 
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While the FTC has had more than ten times as many incoming SAFE WEB secondees as it has sent out, 

FTC employees have worked on 15 temporary SAFE WEB assignments to foreign government agencies 

since 2007.119 FTC staff detailed to foreign government agencies similarly build relationships and gain 

valuable understanding of the policies and practices of foreign enforcement and policy agencies. 

These staff exchanges—now almost 150 of them—have advanced the goal of cross-border cooperation 

to the benefit of U.S. law enforcement and consumers. Through these exchanges, the FTC and foreign 

competition, consumer protection, and privacy agencies have shared best practices, promoted better 

understanding of agency similarities and differences, and deepened their relationships. In addition, the 

understanding gained, and relationships built through these programs, have laid the groundwork for 

cooperation on later enforcement matters. 

Photo 1 (Sunmi Lee of the Korea Fair Trade Commission with then-Commissioner William Kovacic.)

119 FTC secondments abroad have included details with the European Commission and with agencies in Canada, the U.K.,

and Mexico. The FTC also has seconded staff to various agencies in developing countries in connection with USAID 

programs.
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5. Other SAFE WEB Cooperation and Benefits

SAFE WEB permits the FTC to protect certain information from public disclosure, including certain 

confidential information obtained from foreign law enforcement and certain consumer complaints.120

This helps to promote case information sharing that without such confidentiality protections might not 

otherwise occur. It also promotes foreign complaint contributions to Consumer Sentinel, contributing to 

cross-border law enforcement and providing greater insight into cross-border and international fraud. 

SAFE WEB also authorizes the FTC, with the concurrence of the Attorney General, to designate 

Commission attorneys to assist the Attorney General in connection with litigation in foreign courts.121

This provision has resulted in the FTC’s close and frequent collaboration with the Department of 

Justice’s Office of Foreign Litigation (“OFL”), which represents the FTC in its foreign litigation.122 The 

FTC’s collaboration with OFL – an excellent and important resource for FTC matters involving foreign 

service of process and obtaining evidence abroad – has benefitted numerous FTC domestic litigations.123

The ability to engage in foreign litigation has also benefited U.S.-based consumers. Our litigation to stop 

a debt reduction scam in FTC v. E.M.A. Nationwide, Inc.,

124 shows the potential for such action. 

Through participation in Canada regional partnerships, the FTC has nurtured its relationship with 

Canada law enforcement agencies, including in Montreal. These relationships led to cooperation, 

including the RCMP (facilitated by CBC’s Montreal office) alerting the FTC that it had seized over $2 

million in funds covered by an October 2012 FTC asset freeze. With key assistance from OFL, which 

represented the FTC’s interest in the matter, Canada counsel was retained to seek judicial assistance 

from the Canada courts to repatriate the frozen funds to the U.S. In February 2013, a Quebec Court 

issued two Judgments granting the FTC’s motions for judicial assistance to conserve the seized funds 

during the pendency of the FTC’s U.S. action for the potential benefit of the victims. The FTC believes 

that these two judgments were the first time a Quebec court had granted this type of relief in aid of a 

U.S. preliminary injunction. As a result of the FTC’s work with the RCMP and OFL, in December 2015, 

the FTC repatriated the frozen Canadian funds to the U.S. to benefit consumers via an FTC-administered 

redress program.125

III. Recommendations for Congress

We have two recommendations in this Report. First, that Congress should remove the sunset provision 

to the SAFE WEB Act and second that Congress should amend Section 13(b) of the FTC Act to restore 

120 Section 6(b) of the SAFE WEB Act codified at Section 21(f) of the FTC Act, 15 U.S.C. § 57b-2(f). 121 Section 5 of the SAFE WEB Act codified at Section 16 of the FTC Act, 15 U.S.C. § 56. 122 Since 2011, the FTC has had a staff member detailed to the OFL one day per week to represent the FTC’s interests. 123 For example, OFL recently assisted the FTC in hiring an expert on French attorney client privilege issues so that the FTC 

could more effectively respond to discovery objections. This assistance was instrumental in achieving a successful outcome 

in that dispute. 

124 FTC v. E.M.A. Nationwide, Inc., No. 1:12-cv-2394 (N.D. Ohio Sept. 25, 2012). See also FTC, E.M.A. Nationwide, also 

d/b/a EMA and Expense Management America, et al. (May 9, 2016), https://www.ftc.gov/legal-library/browse/casesproceedings/122-3069-ema-nationwide-also-dba-ema-expense-management-america-et-al. 125 See Press Release, FTC, FTC Returns $1.87 Million to Consumers Harmed by Debt Relief Scam (May 9, 2016), 

https://www.ftc.gov/news-events/news/press-releases/2016/05/ftc-returns-187-million-consumers-harmed-debt-relief-scam. 
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the FTC’s ability to provide refunds to harmed consumers and prevent bad actors from keeping money 

generated by breaking the law. 

Since Congress enacted SAFE WEB, FTC Commissioners have repeatedly and on a bipartisan basis 

recognized the Act’s utility and encouraged Congress to make the legislation permanent.126 If this 

legislation were to lapse, the FTC would lack what is now clear authority to pursue many matters 

relating to foreign commerce; this could have a dramatic negative impact on U.S. consumers.127 In 

addition, the FTC’s inability to help foreign partners would hinder its ability to obtain assistance from 

foreign partners. Moreover, many of the international data transfer mechanisms relied on by scores of 

businesses for cross-border commerce – such as the EU-U.S. Data Privacy Framework – would be 

called into question. As cross-border fraud and other misconduct continues to evolve and harm the 

public, it is imperative that Congress preserve the many important tools provided by the U.S. SAFE 

WEB Act, so that the FTC can continue to use those tools to protect the American public. 

As demonstrated by the FTC’s ample record of cross-border fraud enforcement set forth in this report, 

the ability to compensate fraud victims for their losses is a key part of the agency’s work to protect 

American victims from foreign misconduct. Since 2017, the FTC cases have resulted in nearly 12 billion 

dollars returned to victims, including victims of conduct by foreign bad actors. These refunds also 

include over 14 million dollars sent to recipients in over 110 countries, encouraging similar initiatives 

from foreign counterparts.128 

In addition, as the Commission has stated several times in prior congressional testimony, the FTC urges 

Congress to amend Section 13(b) of the FTC Act129 to restore the FTC’s ability to provide refunds to 

harmed consumers and prevent violators from keeping the money they earned by breaking the law. In 

April 2021, the Supreme Court issued its decision in AMG Capital Management v. FTC, which 

overturned four decades of circuit court precedent and held that Section 13(b) of the FTC Act no longer 

allowed courts to order defendants to pay refunds to harmed consumers or order defendants to disgorge 

their unjust gains.

130 That decision has significantly hampered the FTC’s ability to get harmed 

consumers their money back and prevent wrongdoers from profiting from their violations of the FTC 

Act.131 Restoring the FTC’s ability to use Section 13(b) to obtain court orders requiring companies to 

126 See supra note 52. See also, Hearings on Competition and Consumer Protection in the 21st Century, The FTC’s Role in a 

Changing World (Oct. 2020) at 5, https://www.ftc.gov/system/files/documents/reports/commission-report-hearingscompetition-consumer-protection-21st-century/p181201internationalhearingreport.pdf. 127 See Section II.B. See, also, Morrison v. Nat’l Austl. Bank Ltd, 561 U.S. 247, 254-262 (June 24, 2010) (upholding the 

presumption that, absent contrary Congressional intent, legislation does not have extraterritorial effect).

128 See FTC Refunds to Consumers, 

https://public.tableau.com/app/profile/federal.trade.commission/viz/Refunds_15797958402020/RefundsbyCase (last accessed 

Sept. 26, 2023) (these total amounts include money returned to consumers directly by defendants or other third parties in 

certain cases). The U.S. SAFE WEB Act explicitly permits restitution to foreign victims of unfair or deceptive acts or

practices if such relief is available to the Commission. 15 U.S.C. § 45(a)(4)(B). 

129 15 U.S.C. § 53(b). 130 AMG Capital Mgmt., LLC v. FTC, 141 S. Ct. 1341 (Apr. 22, 2021). 131 See, e.g., Press Release, FTC, FTC Order to Bar ZyCal Bioceuticals from Deceptive Health Marketing (Feb. 6, 2023), 

https://www.ftc.gov/news-events/news/press-releases/2023/02/ftc-order-bar-zycalbioceuticals-deceptive-health-marketing
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pay equitable monetary relief is critical to the agency’s ability to protect consumers from cross-border 

fraud.

Conclusion

Cross-border fraud causes significant harm, with consumer reports alone indicating more than $5.2 

billion in injury since 2015. And while often shifting, cross-border fraud shows no sign of abating. The 

U.S. SAFE WEB Act has equipped the FTC to better tackle cross-border fraud by affirming the FTC’s 

authority to pursue harms that cause reasonably foreseeable injury or involve material conduct in the 

U.S. and allowing the FTC to cooperate with foreign law enforcement. It also supports trillions of 

dollars in cross-border commercial transactions. To preserve the FTC’s ability to continue to protect 

American consumers from cross-border fraud and to help promote the exchange of data necessary for 

cross-border commerce, the FTC encourages Congress to make the U.S. SAFE WEB Act permanent. To 

restore the FTC’s ability to provide refunds to injured consumers, the FTC also urges Congress to 

amend Section 13(b) of the FTC Act.

(“Unfortunately, the Supreme Court decision in AMG Capital Management prevented us from obtaining refunds for 

consumers in this case. The Commission has urged Congress to enact legislation to restore the agency’s ability to obtain 

critical relief for consumers through federal court actions.”); Press Release, FTC, Federal Court Rules in Favor of FTC, 

Halting Illegal Tactics Used to Promote Smoking Cessation, Weight-Loss, and Sexual-Performance Aids (Mar. 25, 2022), 

https://www.ftc.gov/newsevents/news/press-releases/2022/03/federal-court-rules-favor-ftc-halting-illegal-tactics-usedpromote-smokingcessation-weight-loss (“[D]espite the fact that the FTC presented evidence that consumers lost $18.2 

million to the defendants’ deceptive marketing, the court declined to order any compensation because of [the] Supreme 

Court’s ruling in the case of AMG v. FTC, which undercuts the agency’s authority to obtain such consumer redress.”)
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Acknowledgments 

This report was drafted by Stacy Procter, Olivia Barney-Fishbein and Laureen Kapin of the FTC’s 

Office of International Affairs. Additional acknowledgement goes to Paul Witt, Elizabeth Anne Miles, 

and Nicholas Mastrocinque of the FTC’s Division of Consumer Response and Operations. 
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Appendix A

Additional Details on Cross-Border and International Fraud Data

Consumer complaints show that cross-border fraud is multifaceted, with U.S. and other consumers 

encountering fraud in various forms and from a multitude of sources. Between January 1, 2019 and June 

30, 2023 (during which complete Sentinel data is currently available) some of the most common frauds 

that U.S. consumers encountered from foreign businesses related to such diverse issues as online 

shopping (e.g., undisclosed costs, failure to deliver on time, non-delivery, and refusal to honor a 

guarantee), impersonation fraud (e.g., romance, tech support, and business and family and friend

imposter scams), unsolicited commercial emails (i.e., spam), miscellaneous investment scams (e.g., 

virtual currencies and investment advice and seminars), and computer exploits (e.g., spyware, adware, 

and malware). Of these frauds, two of the most prevalent reported during this period were online 

shopping and romance scams, with online shopping being the top complaint subcategory for each year 

between 2019 and 2022 and the first half of 2023, and romance scams being either the second or third 

top complaint subcategory each year (after excluding other miscellaneous complaints) and the first half 

of 2023. Statistics and data on the top 10 subcategories of cross-border fraud as reported by U.S. 

consumers for January 1, 2019, to June 30, 2023 (combined) is set forth in Figure 6 below. (Data though 

2022 is current as of August 22, 2023. See note 32, supra, for additional information on fraud reporting 

categories and subcategories.)

Figure 6: Top 10 Cross-Border Fraud Complaint Categories 

from U.S. Consumers

Rank Sentinel Fraud Subcategory Count Percentage of 

Complaints

1 Online Shopping 80,659 29%

2 Other Misc. 40,380 14%

3 Romance Scams 30,003 11%

4 Business Imposters 19,866 7%

5 Misc. Investments & Investment Advice 16,724 6%

6 Tech Support Scams 13,840 5%

7 Unwanted Telemarketing 10,714 4%

8 Unsolicited Email 10,223 4%

9 Family & Friend Imposters 10,192 4%

10 Malware & Computer Exploits 9,135 3%

U.S. consumers also encounter different types of fraud from different countries. For example, in recent 

years, when reporting about fraud originating in China and Canada, the most common frauds reported 
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FEDERAL TRADE COMMISSION • FTC.GOV 34

by U.S. consumers related to online shopping. Complaints by U.S. consumers about businesses in India 

largely involved imposter scams, such as tech support and business imposter scams. And while 

consumers in the U.S. often complain about online shopping frauds originating in the U.K., in 2021 and 

2022 the most common frauds that U.S. consumers reported for companies located in the U.K. related to 

miscellaneous investments, such as investment opportunities in virtual currency and investment advice 

or seminars. Detailed data on the top ten fraud subcategories that U.S. consumers have experienced from 

different countries between 2019 and 2022 is provided in Figure 7. 

Figure 7: Annual Top 10 Fraud Subcategories

as Reported by U.S. Consumers 

2019 2020

Country Complaint Category Complaint 

Total

Country Complaint Category Complaint 

Total

China* Online Shopping 5,731 China* Online Shopping 13,708

Canada Online Shopping 1,847 China* Other Miscellaneous 10,798

China* Other Miscellaneous 1,442 Canada Online Shopping 3,360

India Tech Support Scams 1,314 U.K. Online Shopping 2,459

U.K. Online Shopping 1,233 China* Social Networking 

Services

1,138

Canada Other Miscellaneous 802 Canada Vacation & Travel 1,131

Jamaica Miscellaneous 

Investments & 

Investment Advice

794 Mexico Family & Friend 

Imposters

1,034

Jamaica Advance-Fee Credit 773 Jamaica Prizes, Sweepstakes 

& Lotteries

938

Jamaica Prizes, Sweepstakes 

& Lotteries

766 Canada Other Miscellaneous 857

Nigeria Romance Scams 753 Philippines Romance Scams 799

2021 2022

Country Complaint Category Complaint 

Total

Country Complaint Category Complaint 

Total

China* Online Shopping 8,162 China* Online Shopping 4,321

China* Other Miscellaneous 7,203 U.K. Miscellaneous 

Investments & 

Investment Advice

1,692

Canada Online Shopping 2,215 Canada Online Shopping 1,551

India Business Imposters 1,864 China* Other Miscellaneous 1,532

India Tech Support Scams 1,599 India Tech Support Scams 1,508

U.K. Online Shopping 1,592 India Business Imposters 1,378
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U.K. Miscellaneous 

Investments & 

Investment Advice

1,453 China* Miscellaneous 

Investments & 

Investment Advice

1,320

India Unwanted 

Telemarketing Calls

1,442 U.K. Online Shopping 1,162

Mexico Family & Friend 

Imposters

1,326 Philippines Malware & 

Computer Exploits

1,000

Philippines Romance Scams 1,201 Canada Vacation & Travel 998

(*China includes Hong Kong and Macau.)

International fraud reports more generally (all complaints where the reported consumer or company is 

not from the U.S.) also suggest that in recent years consumers have increasingly been targeted by 

scammers outside of the U.S. through social media, websites, and apps. Since January 1, 2019, U.S. and 

foreign consumers collectively have reported a decrease in international fraud being initiated through 

email and the telephone, and a corresponding increase through other internet-based contact methods, 

such as social media, websites, and apps. In 2019, 25% of consumers who reported an incident of 

international fraud initiating outside of the U.S. reported that they were first contacted via email. By 

June 30, 2023, only about half that many (12%) reported being contacted by email. Similarly, consumers 

have reported a drop from 17% to 8% in scammers initially contacting them by phone. Conversely, 

consumers have reported that contact through social media, websites or apps by scammers located 

outside of the U.S. has increased from 29% in 2019 to 53% by June 30, 2023. Figure 8 shows annual 

and 2023 year-to-date details for the initial contact and payment methods employed by companies 

outside of the U.S. between January 1, 2019, and June 30, 2023. Further information in this format, 

updated quarterly, is available through the “Contact and Payment Method” tab located at 

https://public.tableau.com/app/profile/federal.trade.commission/viz/InternationalReports/TopCountries. 
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Figure 8: Fraud Reports Against non-U.S. Companies

Additional details on recent trends concerning contact and payment methods for fraud originating in 

Canada, China, India, Mexico, and the U.K. – the top five country locations reported by consumers in 

the U.S. since January 1, 2019 – is provided in Figures 9 to 14. (In these international trends, China and 

Hong Kong are reported separately; data for Macau is not available.) Among other things, this data 

shows:

• Consumers often pay scammers in Canada through wire transfer.

• Paying fraudsters in the U.K. and Hong Kong through cryptocurrencies has been common in 

recent years.

• Consumers who report fraud concerning China (excluding Hong Kong and Macau) are often 

contacted via social media or websites, and often pay with credit cards or debit cards.

Further information on these and other countries and regions, updated quarterly, is available by selecting 

specific countries or regions through the “Contact & Payment Method” tab located at 

https://public.tableau.com/app/profile/federal.trade.commission/viz/InternationalReports/TopCountries. 
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Figure 9: Fraud Reports Against Companies Located in Canada
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Figure 10: Fraud Reports Against Companies Located in China
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Figure 11: Fraud Reports Against Companies Located in Hong Kong
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Figure 12: Fraud Reports Against Companies Located in India
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Figure 13: Fraud Reports Against Companies Located in Mexico
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Figure 14: Fraud Reports Against Companies Located 

in the United Kingdom
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Appendix B

Consumer Sentinel and Tableau Public

Consumer complaints, including cross-border complaints, are essential to the FTC’s enforcement efforts, 

providing direct information about fraud and other harms that consumers encounter in the marketplace. 

The FTC and its law enforcement partners – through the Consumer Sentinel system – use and share 

complaints in a secure and confidential manner to identify enforcement targets and, with appropriate 

safeguards, as evidence in enforcement proceedings. The FTC also uses aggregate complaint data—

through the Tableau Public system—to report publicly on complaint and fraud trends. The FTC does 

not act upon individual complaints. 

Consumer Sentinel

Because complaints are so critical to the enforcement efforts of the FTC and its partners, the 

Commission has worked diligently for many years to first create and then expand the number of 

agencies and organizations, both foreign and domestic, that contribute data to or access Consumer 

Sentinel. When Sentinel was launched in 1997, it was the first bi-national web-based fraud database to 

track consumer complaints in multiple jurisdictions. Since then, it has expanded into a robust multinational, multi-state, multi-organization database that receives millions of complaints each year from 45

data contributors (see https://www.ftc.gov/enforcement/consumer-sentinel-network/data-contributors); 

an additional 29 entities also refer consumers to Consumer Sentinel to file complaints. In addition, over 

1,000 law enforcement agencies are registered Sentinel members, including 44 foreign law enforcement 

agencies, with the FTC providing Sentinel access to nearly 3,000 individual law enforcement 

professionals, with hundreds accessing the system weekly. As a result of ongoing improvements to 

Sentinel, these users can securely search, sort and view complaint data tailored to their needs while 

protecting consumer privacy.

How the FTC Receives Complaints

The FTC receives fraud complaints from consumers in both English and various other languages via its 

web-based complaint portal ReportFraud.ftc.gov and phone calls to the FTC’s Consumer Response 

Center. Consumers can also report identity theft at IdentityTheft.gov and unwanted calls to the National 

Do Not Call Registry at donotcall.gov. This data is retained in the FTC’s Consumer Sentinel database, a 

secure online database available only to registered law enforcement agencies and users. (A current list of 

member agencies can be found at https://register.consumersentinel.gov/Agency.) 

In addition to reports received directly from consumers, Consumer Sentinel includes reports filed with 

46 other federal, state, local, and foreign law enforcement agencies, as well as various private 

organizations. (Data contributors that are not enforcement agencies do not have access to the Sentinel 

database.) These contributions greatly improve the quantity and quality of information available to law 

enforcement about fraud and other consumer harms, including cross-border frauds. Important sources of 

cross-border fraud complaints include foreign law enforcement agencies, which are the Canadian 
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 44

Competition Bureau, which has contributed to Sentinel for over two decades, and the Australian 

Competition and Consumer Commission, which became a data contributor in 2021. Combined, 

contributions from foreign law enforcement agencies, which are supported by SAFE WEB (see 15 

U.S.C. § 57b-2(f) (concerning confidentiality, exemption from public disclosure, and material obtained 

from a foreign source)) accounted for 7% of all fraud complaints in Sentinel in 2021 and 2022. Another 

important source is econsumer.gov, a project started in 2001 by members of ICPEN. Through the 

econsumer.gov website, consumers can file cross-border reports and learn other steps to take to combat 

fraud, now in nine languages. Econsumer.gov receives tens of thousands of complaints each year. 

Photo 2 (econsumer.gov homepage showing where consumers can report international scams online.)

How the FTC Uses Complaints

The FTC uses consumer complaints to identify questionable business practices and targets and as 

evidentiary support and leads in its enforcement actions. Consumer complaints often describe the 

harmful practices or conduct consumers experience and provide essential investigation details such as 

business locations, websites, URLs, or apps. In addition, when the FTC needs to move quickly to stop an 

ongoing fraud, consumer complaints can provide critical evidence of the unfair or deceptive conduct and 

the extent of consumer harm. And when defendants lack the information necessary to provide consumer 

redress, complaints sometimes help to identify injured consumers. 

The FTC also uses and acts on consumer complaints by sharing them in a secure, confidential manner 

with qualified law enforcement partners through Sentinel, which helps to make law enforcement more 

cooperative and effective. In addition to numerous domestic agencies, several Canadian and Australian 

agencies can access consumer complaints through Sentinel. The FTC has also worked through ICPEN to 
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 45

expand foreign law enforcement access to cross-border complaints, including through econsumer.gov, 

and ICPEN members that have agreed to confidentiality and data security requirements can access 

econsumer.gov complaints through Sentinel. Combined, 44 foreign law enforcement agencies are 

registered Sentinel users. 

Tableau Public Page

In addition to providing confidential access to complaints, as described above, and sharing complaints 

through SAFE WEB, the FTC also analyzes consumer complaints to identify and make public aggregate 

trend data. For example, consumer complaints housed in Sentinel can be analyzed by various attributes, 

including 100 fraud and other subcategories (such as online shopping and imposter scams), as well as 

business location, consumers location, complaint source, contact and payment methods, and more. 

For over two decades, the FTC has publicly reported on aggregate complaint trends through its 

Consumer Sentinel Network Reports (see https://www.ftc.gov/enforcement/consumer-sentinelnetwork/reports) and Annual Reports (see https://www.ftc.gov/policy/reports/ftc-annual-reports). In 

2018, as part of its ongoing efforts to improve on its ability to analyze, report on, and share aggregate 

public information about consumer complaints, the FTC launched its interactive Tableau Public page

(available at

https://public.tableau.com/app/profile/federal.trade.commission/viz/federal.trade.commission#!/). 

Through the FTC’s Tableau Public page, members of the public can view up to five years of annual and 

quarterly complaint data through multiple interactive visualizations. This includes data on international 

complaints. Thus, for example, through the FTC’s International Reports visualizations, the public can 

see fraud reports against the top 50 non-U.S. locations through a table and an interactive map where, by 

simply clicking on a country, responsive data for that country appears. (See Figures 15 and 16.) The 

public can also find data visualizations about the most common contact methods and payment methods 

used when consumers interact with non-U.S. companies (see Appendix A) and summaries of complaints 

to the econsumer.gov website.
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 46

Figure 15: Fraud Reports Against Top 50 non-U.S. Company 

Locations
The U.S. SAFE WEB Act and the FTC’s Fight Against Cross-Border Fraud

FEDERAL TRADE COMMISSION • FTC.GOV 47

Figure 16: Fraud Reports Against Top 50 non-U.S. Company 

Locations
Appendix C

FTC Enforcement Actions with Public Cross-Border Compone

(Cases filed between January 1, 2007, and June 30, 2023) 

This list includes cases filed in which public information indicates that one or more of the defendants is located a

some other significant foreign component, such as key foreign witnesses or other important evidence located abr

of foreign victims, efforts to recover substantial foreign assets, or substantial investigative assistance by a foreign 

authority. It does not attempt to capture every case involving foreign victims, foreign evidence, or foreign assets; 

some such connection, but this information is not always disclosed publicly. 

Case Caption Noteworthy Conduct 

and Relief 

Cross-Border 

Component(s) 

Initial Press Release 

Through June 30, 2022

1 U.S. v. Nexway SASU, 

No. 1:23-cv-900 

(D.D.C. Apr. 3, 2023)

Defendants, a multinational payment 

processing company, its 

CEO, and chief strategy 

officer, are alleged to have 

facilitated tech support 

scammers through credit 

card laundering, going 

back to at least 2016. 

Defendant Nexway SASU 

is a French corporation 

which became part of 

defendant Nexway Group 

AG, a Swiss corporation 

in 2018. Defendant asknet 

Solutions AG is a German 

corporation. 

FTC Acts to Block Payment 

Processor’s Credit Card 

Laundering for Tech Suppor

Scammers

2 U.S. v. Stratics 

Networks, Inc., No. 

3:23-cv-00313-BASKSC (S.D. Cal. Feb. 

16, 2023) 

Defendants, an outbound 

calling service, are alleged 

to have assisted and 

facilitated violations of the 

Telemarketing Sales Rule 

(“TSR”) by enabling its 

clients to route and 

transmit millions of 

Defendant Stratics

Networks is a Canadian 

corporation. 

FTC Sues to Stop 

Interconnected Web of VoIP 

Service Providers Carrying 

Robocalls Pitching Phony 

Debt Relief Services

FEDERAL TRADE COMMISSION • FTC.GOV 48
robocalls using VoIP 

technology. 

3 FTC v. WealthPress, 

Inc., No. 3:23-cv00046 (M.D. Fl. Jan. 

12, 2023) 

Defendants, an investment 

advice company and its 

owners, were alleged to 

have made deceptive 

claims to sell consumers 

investment advising 

services that cost 

consumers hundreds or 

thousands of dollars. 

A settlement order 

requires defendants to 

refund more than $1.2 

million to consumers and 

pay a $500,000 civil 

penalty for deceiving 

consumers with false 

claims about their 

services. 

Defendant Conor Lynch 

owned one third of Wealth 

Press through a Canadian 

based company Happy 

Camper Publishing, Inc. 

FTC Suit Requires 

Investment Advice Company 

WealthPress to Pay $1.7 

Million for Deceiving 

Consumers 

2022

4 In the Matter of 

Electrowarmth Prods., 

LLC, File No. 222-

3096, Docket No. C4779 (Aug. 30, 2022) 

Respondents were alleged 

to have deceptively 

claimed that products were 

“made in the USA” when 

they were made in China. 

Settlement prohibits 

respondents from making 

misleading or 

unsubstantiated country of 

origin claims. 

Respondent 

Electrowarmth’s heated

fabric mattress pad 

products were wholly 

manufactured, labeled, 

and packaged in China. 

FTC Sues Heated Mattress 

Pads Marketer 

Electrowarmth for Falsely 

Claiming that Chinese 

Products Were Made in the 

USA 

FEDERAL TRADE COMMISSION • FTC.GOV 49
5 FTC v. Walmart Inc., 

No. 1:22-cv-3372 

(N.D. Ill. June 28, 

2022) 

Defendant alleged to have 

injured consumers by 

failing to take timely, 

appropriate, and effective 

action to detect and 

prevent fraud-induced 

money transfers, and to 

have assisted and 

facilitated violations of the 

TSR through the 

processing of money 

transfers. 

Walmart transacted 

business throughout the 

United States and in other 

countries worldwide, 

including by offering and 

facilitating money transfer 

services around the 

world. 

FTC Sues Walmart for 

Facilitating Money Transfer 

Fraud That Fleeced 

Customers Out of Hundreds 

of Millions 

6 FTC v. Warrior 

Trading Inc., No. 3:22-

cv-30048 (D. Mass. 

Apr. 19, 2022) 

Defendants, an alleged 

day-trading investment 

scheme, made misleading 

and unrealistic claims of 

big investment gains to 

consumers who paid 

hundreds or thousands of 

dollars for a system that 

ultimately failed to pay off 

for most customers. 

As a result of a settlement, 

Warrior Trading was 

required to pay $3 million 

to refund consumers and 

was prohibited from 

making baseless claims 

about the potential for 

consumers to earn money 

using their trading 

strategies. 

Defendants advertised, 

marketed, promoted, and 

sold their day-trading 

strategies and related 

goods and services to 

consumers throughout the 

United States and 

internationally. 

Federal Trade Commission 

Cracks Down on Warrior 

Trading for Misleading 

Consumers With False 

Investment Promises 

FEDERAL TRADE COMMISSION • FTC.GOV 50
7 FTC v. Hum. Res. Dev. 

Servs., Inc., also d/b/a 

Saint James Sch. of 

Med., No. 1:22-cv1919, (N.D. Ill. Apr. 

14, 2022) 

Defendants alleged to 

have deceptively marketed 

their school’s medical 

license exam test pass rate 

and residency matches to 

lure prospective students. 

Defendants also alleged to 

have violated the Holder 

Rule, which preserves 

rights for injured 

consumers, and the Credit 

Practices Rule, which 

protects consumers in 

credit contracts. 

Settlement bans 

defendants from 

misrepresenting medical 

license test pass rates, 

residency matches, and 

making unsubstantiated 

claims, and ordered them 

to pay $1.2 million in 

redress. 

Saint James School of 

Medicine is a for-profit 

medical school in the 

Caribbean. 

Federal Trade Commission 

Takes Action Against ForProfit Medical School for 

Using Deceptive Marketing 

to Lure Students 

8 U.S. v. Turbo Sols. 

Inc., f/k/a Alex Miller 

Fin. Serv., No. 4:22-

mc-369 (S.D. Tex. 

Mar. 1, 2022) 

Defendants alleged to 

have defrauded consumers 

out of millions of dollars 

by falsely claiming they 

would remove negative 

information from credit 

reports in exchange for a 

fee. Defendants also 

alleged to have filed fake 

identity theft reports to 

explain negative items on 

Turbo Solutions 

employees or contractors 

operated from the 

Philippines. 

FTC Halts Deceptive Credit 

Repair Operation that Filed 

Fake Identity Theft 

Complaints 

FEDERAL TRADE COMMISSION • FTC.GOV 51
customers’ credit 

reports. 

9 In the Matter of 

Fashion Nova, Inc., 

File No. 192-3138, 

Docket No. C-4759 

(Jan. 25, 2022) 

Respondent, an online 

fashion retailer, was 

alleged to have engaged in 

deceptive review practices 

by only publishing fourand five-star customer 

reviews of products and 

by suppressing thousands 

of lower starred, negative 

reviews. 

Settlement required 

respondent to pay $4.2 

million for the harm it 

caused consumers. 

Fashion Nova transacted 

business throughout the 

United States and in other 

countries worldwide. 

Fashion Nova will Pay $4.2 

Million as part of Settlement 

of FTC Allegations it 

Blocked Negative Reviews 

of Products 

2021

10 U.S. v. Kuuhuub Inc., 

No. 1:21-cv-01758 

(D.D.C. July 1, 2021) 

(a/k/a Recolor Oy) 

Defendants, operators of 

an online coloring book 

app, were alleged to have 

violated the Children’s 

Online Privacy Protection 

Act (COPPA) Rule by 

collecting and disclosing 

personal information 

about children who used 

the app without notifying 

their parents and obtaining

consent. 

Settlement required 

defendants to notify 

Defendant Kuuhuub Inc. 

is a Canadian corporation. 

Defendants Kuu Hubb Oy 

and Recolor Oy are 

Finnish subsidiaries of 

Kuuhuub Inc. 

Online Coloring Book App 

Recolor Settles FTC 

Allegations It Illegally 

Collected Kids’ Personal 

Information 

FEDERAL TRADE COMMISSION • FTC.GOV 52
parents and offer refunds 

for underage subscribers. 

11 In the Matter of BASF 

SE, File No. 192-3088, 

Docket No. C-4744, C4745 (Apr. 1, 2021). 

Respondents alleged to 

have deceptively marketed 

fish oil supplements as 

clinically proven to reduce 

liver fat in adults and 

children with nonalcoholic fatty liver 

disease. 

Settlements ban the 

companies from making 

unproven health claims 

and require them to pay 

over $416,000 – enough 

money to provide full 

refunds to over 1,800 

consumers nationwide. 

BASF SE is multi-national 

corporation based in 

Germany. 

Companies Settle FTC 

Charges that They 

Deceptively Marketed Fish 

Oil Supplements with False 

Claims They Were Clinically 

Proven to Treat Liver 

Disease 

12 In the Matter of 

Residual Pumpkin 

Entity, LLC, formerly 

d/b/a CafePress, File 

No. 192-3209, Docket 

Nos. C-4768, C-4769 

(Mar. 15, 2021) 

Respondents alleged to 

have failed to implement 

reasonable security 

measures to protect 

sensitive information 

stored on CafePress’s 

network and to have 

covered up a major breach 

that included plain text 

Social Security numbers, 

inadequately encrypted 

passwords, and answers to 

password reset questions. 

Respondents also alleged 

Respondents 

misrepresented their 

adherence to the EU-U.S. 

and Swiss-U.S. Privacy 

Shield frameworks and 

misrepresented that they 

would honor requests 

from residents of the EU 

and Switzerland to erase 

and restrict the use of 

personal data. 

FTC Takes Action Against 

CafePress for Data Breach 

Cover Up 

FEDERAL TRADE COMMISSION • FTC.GOV 53
to have misrepresented 

their adherence to the EUU.S. Privacy Shield and 

Swiss-U.S. Privacy Shield 

frameworks. 

Settlement ordered 

respondents to implement 

comprehensive 

information security 

programs and Respondent 

Residual Pumpkin 

(CafePress) ordered to pay 

$500,000 to victims of 

data breach. 

13 In the Matter of Flo 

Health, Inc., File No. 

192-3133, Docket No. 

C-4747 (Jan. 13, 2021)

Respondent, the developer 

of a popular fertility 

tracking app, allegedly 

promised to keep users’ 

health data private and 

only use it for app 

services, but instead 

disclosed it to third parties 

that provided marketing 

and analytics services. 

Respondent also alleged to 

have violated the EU-U.S. 

Privacy Shield and SwissU.S. Privacy Shield 

frameworks. 

Settlement required the 

respondent to obtain the 

affirmative consent of its 

users before sharing their 

Data transfers under the 

EU-U.S. Privacy Shield 

and Swiss-U.S. Privacy 

Shield frameworks. 

Respondent’s Flo app was 

downloaded by more than 

19 million users in the EU 

and Switzerland. 

Developer of Popular 

Women’s Fertility-Tracking 

App Settles FTC Allegations 

that It Misled Consumers 

About the Disclosure of their 

Health Data 

FEDERAL TRADE COMMISSION • FTC.GOV 54
personal health 

information and to obtain 

an independent review of 

its privacy practices. 

2020

14 In the Matter of 

Ascension Data & 

Analytics, LLC, File 

No. 192-3126, Docket 

No. C-4758 (Dec. 15, 

2020) 

Respondents, a mortgage 

industry data analytics 

company, allegedly failed 

to ensure that one of its 

vendors, which was hired 

to perform text recognition 

scanning, was adequately 

securing personal data 

about tens of thousands of 

mortgage holders in 

violation of the GrammLeach Bliley Act’s 

Safeguards Rule. The 

cloud-based server that 

stored the data in plain 

text and without other 

protections was accessed 

roughly 52 times by 

unauthorized IP addresses, 

including from Russia and 

China. 

The settlement requires 

the company to bolster its 

data security protections 

and oversight of its 

vendors to ensure thirdparty providers are also 

Unauthorized IP addresses 

from Russia and China 

accessed a cloud-based 

server that stored personal 

data on tens of thousands 

of consumers in plain text 

and without other 

protections 

Mortgage Analytics 

Company Settles FTC 

Allegations It Failed to 

Ensure Vendor Was 

Adequately Protecting 

Consumer Data 

FEDERAL TRADE COMMISSION • FTC.GOV 55
complying with those 

safeguards. 

15 In the Matter of 

Miniclip S.A., File No. 

192-3129, Docket No. 

C-4722 (May 19, 

2020) 

Respondent, a digital 

game developer, was 

alleged to have falsely 

claimed, from 2015 

through mid-2019, that it 

was a member of the 

Children’s Advertising 

Review Unit’s (CARU) 

COPPA safe harbor 

program despite its 

membership having been 

terminated in 2015. 

Miniclip is prohibited 

from misrepresenting its 

participation or 

certification in any privacy 

or security program 

sponsored by a 

government or any selfregulatory organization, 

including the CARU 

COPPA safe harbor 

program 

Respondent Miniclip is a 

Swiss corporation. 

Swiss Digital Game 

Developer Settles FTC 

Allegations that it Falsely 

Claimed it was a Member of 

COPPA Safe Harbor 

Program 

16 FTC v. Fashion Nova, 

Inc., No. 2:20-cv-3641 

(C.D. Cal. Apr. 20, 

2020) 

Defendant, an online 

fashion retailer, was 

alleged to have failed to 

notify consumers and give 

them the opportunity to 

cancel their orders when 

the company did not ship 

ordered merchandise in a 

Fashion Nova marketed 

and sold merchandise to 

consumers throughout the 

United States and in many 

other countries. 

Consumers in over fifty 

countries complained 

about Fashion Nova’s 

Fashion Nova Will Pay $9.3 

Million for Consumer 

Refunds To Settle FTC 

Charges It Violated Rules On 

Shipping, Refunds 

FEDERAL TRADE COMMISSION • FTC.GOV 56
timely manner. Defendant 

were also alleged to have 

illegally issued gift cards 

to compensate consumers 

for unshipped 

merchandise instead of 

providing refunds. 

As part of a settlement, the 

defendant was ordered to 

pay $9.3 million. 

practices and the FTC 

provided redress to 

consumers in 169 different 

countries. 

17 FTC v. Bransfield, No. 

6:20-cv-00372 (M.D. 

Fla. Mar. 3, 2020) 

Defendants, affiliate 

marketers for the business 

coaching and investment 

scheme known as “My 

Online Business 

Education” (MOBE), were

alleged to have helped 

deceive consumers by 

making false and 

misleading earnings 

claims. 

Settlement orders 

permanently ban 

defendants from selling or 

marketing any business 

coaching program or 

money-making method. 

Defendant John Chow and 

his company TTZ Media 

were ordered to pay $3.35 

million for consumer 

redress. 

Defendant TTZ Media is a 

Canadian corporation. 

Affiliate Marketers to Pay 

More Than $4 Million to 

Settle Charges that They 

Promoted a Fraudulent 

Business Coaching and 

Investment Scheme 

FEDERAL TRADE COMMISSION • FTC.GOV 57
18 FTC v. OTA Franchise 

Corp., No. 8:20-cv00287-JVS (C.D. Cal. 

Feb. 12, 2020) 

Defendants alleged to 

have deceived consumers 

with false and 

unsubstantiated claims 

that purchasers of the 

Online Trading 

Academy’s (OTA) 

investment training were 

likely to earn significant 

income. Defendants also 

alleged to have illegally 

used form contracts to 

prevent consumers from 

complaining to the 

government or others 

about OTA’s deception. 

Defendants were ordered, 

as part of a settlement, to 

forgive $13.3 million in 

debt owed by consumers. 

Defendants advertised, 

marketed, distributed, 

promoted, and sold their 

training programs to 

consumers throughout the 

United States and 

internationally, and 

operated training centers 

in Vancouver, Canada and 

London, England. 

FTC Sues Online Trading 

Academy for Running an 

Investment Training 

Scheme 

19 FTC v. Noland, No. 

CV-20-0047-PHXDWL (D. Ariz. Jan. 21, 

2020) (complaint 

amended Sep. 24, 

2020) (a/k/a Success by 

Health) 

Defendants operated 

“instant coffee” and travel 

pyramid schemes that used 

false promises of wealth 

and income to entice 

thousands of consumers to 

join. 

After a trial, the court 

imposed a $7.3 million 

monetary judgment on 

defendants, and 

permanently banned 

defendants from any 

The FTC presented 

evidence of defendant 

Noland’s efforts to move 

assets abroad and relocate 

to Uruguay. In granting 

the FTC’s preliminary 

injunction, the court found 

that defendant Noland 

used corporate funds to 

pay for homes in the 

United States and 

Uruguay. 

FTC Acts to Shut Down 

‘Success by Health’ Instant 

Coffee Pyramid Scheme 

FEDERAL TRADE COMMISSION • FTC.GOV 58
participation in multi-level 

marketing. 

2019

20 FTC v. On Point Glob. 

LLC, No.1:19-cv25046-RNS (S.D. Fla. 

Dec. 12, 2019) 

Defendants deceptively 

operated hundreds of fake 

government websites that 

promised quick and easy 

services, such as renewing 

a driver’s license, but 

instead provided only 

publicly available, general 

information about the 

sought service. 

The FTC’s trial win 

against On Point Global 

made $102 million in 

refunds available to 

consumers who were 

harmed by defendants. 

Defendants owned 

subsidiaries and ran a web 

development office and 

call centers in Costa Rica 

and Uruguay. Defendants 

also established holding 

companies in Nevis (part 

of Saint Kitts and Nevis), 

Belize, and the Bahamas 

to shelter the proceeds of 

the fraud. 

Court Stops Sprawling 

Scheme That Operated 

Hundreds of Websites That 

Deceived Consumers About 

Government Services 

21 In the Matter of NTT 

Global Data Centers 

Americas, Inc., as 

successor in interest to 

RagingWire Data 

Centers, Inc., File No. 

182-3189, Docket No. 

9386 (Nov. 7, 2019) 

Respondent alleged to 

have misled consumers 

about its participation in 

the EU-U.S. Privacy 

Shield framework and 

failed to adhere to the 

program’s requirements 

before allowing its 

certification to lapse. 

Under a settlement, the 

company is prohibited 

from misrepresenting its 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

FTC Charges Nevada 

Company with Falsely 

Claiming Participation in the 

EU-U.S. Privacy Shield 

FEDERAL TRADE COMMISSION • FTC.GOV 59
compliance with or 

participation in the 

Privacy Shield framework, 

and any other privacy or 

data security program 

sponsored by the 

government or any selfregulatory or standardsetting organization. 

22 In the Matter of DCR 

Workplace, Inc., File 

No. 182-3188, Docket 

No. C-4698 (Sept. 3, 

2019) 

Respondent alleged to 

have falsely claimed 

certification under the EUU.S. Privacy Shield 

framework. 

Under the terms of a 

settlement, the company is 

prohibited from 

misrepresenting its 

participation in the EUU.S. Privacy Shield 

framework, any other 

privacy or data security 

program sponsored by the 

government, or any selfregulatory or standardsetting organization. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

Five Companies Settle FTC 

Allegations that they Falsely 

Claimed Participation in the 

EU-U.S. Privacy Shield 

23 In the Matter of 214 

Techs., Inc., also d/b/a 

Trueface.ai, File No. 

182-3193, Docket No. 

C-4699 (Sept. 3, 2019) 

Respondent alleged to 

have falsely claimed 

certification under the EUU.S. Privacy Shield 

framework. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

Five Companies Settle FTC 

Allegations that they Falsely 

Claimed Participation in the 

EU-U.S. Privacy Shield 

FEDERAL TRADE COMMISSION • FTC.GOV 60
Under the terms of a 

settlement, the company is 

prohibited from 

misrepresenting its 

participation in the EUU.S. Privacy Shield 

framework, any other 

privacy or data security 

program sponsored by the 

government, or any selfregulatory or standardsetting organization. 

24 In the Matter of 

LotaData, Inc., File 

No. 182-3194, Docket 

No. C-4700 (Sept. 3, 

2019) 

Respondent alleged to 

have falsely claimed 

certification under the EUU.S. and Swiss-U.S. 

Privacy Shield 

framework. 

Under the terms of a 

settlement, the company is 

prohibited from 

misrepresenting its 

participation in the EUU.S. Privacy Shield 

framework, any other 

privacy or data security 

program sponsored by the 

government, or any selfregulatory or standardsetting organization. 

Data transfers under the 

EU-U.S. and Swiss-U.S. 

Privacy Shield 

framework. 

Five Companies Settle FTC 

Allegations that they Falsely 

Claimed Participation in the 

EU-U.S. Privacy Shield 

FEDERAL TRADE COMMISSION • FTC.GOV 61
25 In the Matter of 

EmpiriStat, Inc., File 

No. 182-3195, Docket 

No. C-4701 (Sept. 3, 

2019) 

Respondent, among other 

things, was alleged to have 

falsely claimed that it was 

a current participant in 

Privacy Shield after 

allowing its certification to 

lapse. 

Under the terms of a 

settlement, the company is 

prohibited from 

misrepresenting its 

participation in the EUU.S. Privacy Shield 

framework, any other 

privacy or data security 

program sponsored by the 

government, or any selfregulatory or standardsetting organization. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

Five Companies Settle FTC 

Allegations that they Falsely 

Claimed Participation in the 

EU-U.S. Privacy Shield 

26 In the Matter of Thru, 

Inc., File No. 182-

3196, Docket No. C4702 (administrative 

complaint filed Sept. 3, 

2019) 

Respondent alleged to 

have falsely claimed 

certification under the EUU.S. Privacy Shield 

framework. 

Under the terms of a 

settlement, the company is 

prohibited from 

misrepresenting its 

participation in the EUU.S. Privacy Shield 

framework, any other 

privacy or data security 

program sponsored by the 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

Five Companies Settle FTC 

Allegations that they Falsely 

Claimed Participation in the 

EU-U.S. Privacy Shield 

FEDERAL TRADE COMMISSION • FTC.GOV 62
government, or any selfregulatory or standardsetting organization. 

27 In the Matter of Kogan, 

File Nos. 182-3106 and 

182-3107, Docket Nos. 

C-4693 and C-4694 

(July 24, 2019) 

Respondents, former 

Cambridge Analytica

CEO Alexander Nix and 

app developer Aleksandr 

Kogan, were alleged to 

have employed deceptive 

tactics to harvest personal 

information from tens of 

millions of Facebook users 

for voter profiling and 

targeting. 

As part of a settlement, 

Kogan and Nix are 

prohibited from making 

false or deceptive 

statements regarding the 

extent to which they 

collect, use, share, or sell 

personal information, as 

well as the purposes for 

which they collect, use, 

share, or sell such 

information. In addition, 

they are required to delete 

or destroy any personal 

information collected from 

consumers via Kogan’s 

GSRApp, which connects 

individuals to their 

Facebook profiles, and 

any related work product 

Respondent Nix is a 

British citizen and was 

residing in the United 

Kingdom (U.K.”). 

Respondent Kogan was 

the owner and co-founder 

of the now-defunct U.K. 

corporation, Global 

Science Research, Ltd.

(GSR). 

FTC Sues Cambridge 

Analytica, Settles with 

Former CEO and App 

Developer 

FEDERAL TRADE COMMISSION • FTC.GOV 63
that originated from the 

data. 

28 In the Matter of 

Cambridge Analytica, 

LLC, File No. 182-

3107, Docket No. 9383 

(July 22, 2019) 

Respondent, a data 

analytics company, was 

found by the FTC to have 

employed deceptive 

tactics to harvest personal 

information from tens of 

millions of Facebook users 

for voter profiling and 

targeting. Respondent also 

found by the FTC to have 

falsely claimed, until at 

least November 2018, that 

it was a participant in the 

EU-U.S. Privacy Shield 

framework, despite 

allowing its certification to 

lapse in May 2018. 

The FTC’s Final Order 

prohibits the company 

from making 

misrepresentations about 

the extent to which it 

protects the privacy and 

confidentiality of personal 

information, as well as its 

participation in the EUU.S. Privacy Shield 

framework and other 

similar regulatory or 

standard-setting 

organizations. The 

company is also required 

Respondent company is 

part of a privately held 

U.K. corporation. 

FTC Sues Cambridge 

Analytica, Settles with 

Former CEO and App 

Developer 

FEDERAL TRADE COMMISSION • FTC.GOV 64
to continue to apply 

Privacy Shield protections 

to personal information it 

collected while 

participating in the 

program (or to provide 

other protections 

authorized by law) or 

return or delete the 

information. It also must 

delete the personal 

information that it 

collected through the 

GSRApp, which connects 

individuals to their 

Facebook profiles. 

29 FTC v. Madera Merch. 

Servs., LLC, No. 3:19-

cv-00195-KC (W.D. 

Tex. July 19, 2019) 

Defendants, Madera 

Merchant Services and 

B&P Enterprises, were 

alleged to have generated 

and processed remotely 

created payment orders 

(RCPOs) that allowed 

deceptive telemarketing 

schemes, including 

American Financial 

Benefits Center, Impetus 

Enterprise and Educare 

Centre Services, to 

withdraw money from 

their victims’ bank 

accounts. 

Under terms of a 

settlement order, 

Defendants processed 

payments for foreign 

enterprise Educare Centre 

Services, which was one 

of its largest clients and 

was based out of Canada 

and the Dominican 

Republic. 

FTC and Ohio Stop Rogue 

Payment Processor and a 

Credit Card InterestReduction Telemarketing 

Scheme that Allegedly 

Worked Together to Scam 

Consumers 

FEDERAL TRADE COMMISSION • FTC.GOV 65
defendants were banned 

from payment 

processing. 

30 FTC v. Educare Ctr. 

Servs., Inc., No. 3:19-

cv-00196-KC (W.D. 

Tex. July 18, 2019) 

Defendants alleged to 

have sold sham credit card 

interest rate reduction 

services to consumers and 

to have violated the TSR, 

including by failing to 

access to the FTC’s Do 

Not Call Registry. Under 

the terms of settlement 

orders, defendants were 

prohibited from 

participating in any 

telemarketing in the 

United States and from 

marketing debt relief 

products or services of any 

kind. 

Defendants Educare (a 

New Jersey company) and 

Prolink Vision (a 

Dominican Republic 

company) were alleged to 

have operated from 

Canada. Four Canadian 

citizens were also alleged 

to have managed and 

controlled the scheme 

from Canada. And a 

Canadian relief defendant 

received over $1 million 

from the scheme. 

FTC and Ohio Stop Rogue 

Payment Processor and a 

Credit Card InterestReduction Telemarketing 

Scheme that Allegedly 

Worked Together to Scam 

Consumers 

31 In the Matter of 

SecurTest, Inc., File 

No. 182-3152, Docket 

No. C-4685 (June 14, 

2019) 

Respondent, which offered 

background screening 

services, was alleged to 

have falsely claimed that it 

complied with the EUU.S. Privacy Shield and 

Swiss-U.S. Privacy Shield 

frameworks. 

A settlement with the 

company prohibits 

SecurTest from 

misrepresenting its 

participation in any 

Data transfers under the 

EU-U.S. and Swiss-U.S. 

Privacy Shield 

framework. 

FTC Takes Action against 

Companies Falsely Claiming 

Compliance with the EUU.S. Privacy Shield, Other 

International Privacy 

Agreements 

FEDERAL TRADE COMMISSION • FTC.GOV 66
privacy or security 

program sponsored by a 

government, selfregulatory, or standardsetting organization, 

including the EU-U.S. 

Privacy Shield and SwissU.S. Privacy Shield 

frameworks. 

32 FTC v. AlliedWallet 

Inc., No. 2:19-cv-4355 

(C.D. Cal. May 20, 

2019) 

Defendants alleged to 

have knowingly processed 

payments and hidden the 

activities of fraudulent 

merchants, including those 

of Stark Law, MOBE and 

Digital Altitude, which 

were subject to FTC 

enforcement actions. 

Pursuant to settlements, a 

$110 million monetary 

judgment was entered 

against Allied Wallet and 

its CEO, and Allied 

Wallet’s COO was banned 

from payment processing 

and ordered to pay $1 

million to the FTC. 

Defendants Allied Walled 

Ltd. and GTBill, Ltd. are 

U.K. companies. 

Operators of Payment 

Processing Firm Settle 

Charges for Assisting 

Fraudulent Schemes that 

Took More than $110 

Million from Consumers 

33 U.S. v. Musical.ly Inc., 

No. 2:19-cv-1439 

(C.D. Cal. Feb. 27, 

2019) 

Defendants, operators of 

the social networking app 

Musical.ly (now known as 

TikTok), were alleged to 

have illegally collected 

personal information from 

Defendant, Musical.ly is a 

Cayman Islands 

corporation, with its 

principal place of business 

in Shanghai, China. 

Video Social Networking 

App Musical.ly Agrees to 

Settle FTC Allegations That 

it Violated Children’s 

Privacy Law 

FEDERAL TRADE COMMISSION • FTC.GOV 67
children in violation of 

COPPA. Despite being 

aware that children were 

using the app, defendants 

also allegedly failed to 

obtain parental consent 

required under COPPA. 

As part of a settlement, 

Defendants were ordered 

to pay a $5.7 million 

penalty, comply with 

COPPA, and remove all 

videos made by children 

under the age of 13. 

2018

34 FTC v. Apex Cap. 

Grp., LLC, No. CV18-

09573-JFW(JPRx) 

(C.D. Cal. Nov. 13, 

2018) (complaint 

amended May 30,

2019) 

Defendants were alleged 

to have run a multinational internet scheme 

that offered “free trials” 

for personal care products 

and dietary supplements, 

but then charged 

consumers full price and 

enrolled them in negative 

option continuity plans 

without their consent. The 

Defendant established 

shell companies in the 

U.S. and UK to open 

merchant accounts, and 

processed payments 

Defendants used shell 

companies in the U.K. and 

a Latvia payment 

processor to process 

millions of dollars in 

consumer payments. 

Court Temporarily Halts 

International Operation that 

Allegedly Deceived 

Consumers through False 

Claims of “Free Trial” Offer

and Imposed Unauthorized 

Continuity Plans 

FEDERAL TRADE COMMISSION • FTC.GOV 68
through a Latvian 

financial institution. 

Defendant, Apex Capital, 

ordered to surrender assets 

valued between $3 million 

to $6 million as part of 

settlement agreement. 

Payment processor, 

Transact Pro, ordered to 

pay $3.5 million. 

35 In re Sanctuary Belize 

Litigation, No. 1:18-

cv-3309 (D. Md. Oct. 

31, 2018) (complaint 

amended Jan. 15, 

2019) 

Defendants, including 

FTC recidivist Andris 

Pukke, deceptively 

marketed lots in what 

supposedly would become 

a luxury development in 

Central America known 

by several names, 

including “Sanctuary 

Belize,” taking in more 

than $100 million from 

consumers. 

In August 2020, the 

district court issued a 

verdict, finding in favor of 

the FTC. After an appeal, 

the district court entered 

an order confirming that 

defendants Andris Pukke, 

Peter Baker, and John 

Usher must turn over 

$120.2 million as well as 

the corporate defendants 

Multi-million dollar crossborder scheme involving 

property purchases in 

Belize. Foreign defendants 

located in Belize and 

Nevis. 

At FTC’s Request, Court 

Halts Massive “Sanctuary 

Belize” Real Estate 

Investment Scam 

FEDERAL TRADE COMMISSION • FTC.GOV 69
and their assets to 

compensate their victims. 

Defendant Chadwick 

settled, turning over 

certain assets, and 

agreeing to an order 

limiting the types of 

business he can engage 

in. 

Defendant Atlantic 

International Bank 

Limited (AIBL) of Belize 

also alleged to have 

assisted and facilitated the 

Sanctuary Belize scheme. 

As part of a 

settlement, AIBL agreed 

to pay $23 million, 

representing 

approximately all of its 

U.S.-based assets, to settle 

charges that it assisted the 

Sanctuary Belize 

enterprise in deceiving 

U.S. consumers. 

36 FTC v. Cardiff, No. 

5:18-cv-02104-SJOPLA (C.D. Cal. Oct. 3, 

2018) (a/k/a Redwood 

Scientific 

Technologies, Inc.) 

Defendants deceptively 

marketed dissolvable oral 

film strips as smoking 

cessation, weight loss, and 

sexual performance 

products and enrolled 

consumers in auto-ship 

continuity plans without 

Defendants violated 

temporary restraining 

order by attempting to 

hide their control of a 

Canadian company in 

order to hide assets. 

At FTC’s Request, Court 

Stops False Advertising and 

Unauthorized Billing 

Scheme; FTC, Law 

Enforcement Partners 

Announce New Crackdown 

on Illegal Robocalls 

FEDERAL TRADE COMMISSION • FTC.GOV 70
their express informed 

consent. 

Defendants permanently 

banned from engaging in 

multi-level marketing, 

robocalls, negative option 

sales, and marketing, 

advertising, or selling thin 

film strips. 

37 In the Matter of 

mResource LLC, also 

d/b/a Loop Works LLC, 

File No. 182-3143, 

Docket No. C-4663 

(Sept. 27, 2018) 

Respondents alleged to 

have falsely claimed to be 

certified under the EUU.S. Privacy Shield 

framework. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

FTC Reaches Settlements 

with Four Companies That 

Falsely Claimed Participatio

in the EU-U.S. Privacy 

Shield 

38 In the Matter of 

VenPath Inc., File No. 

182-3144, Docket No. 

C- 4664 (Sept. 27, 

2018) 

Respondents alleged to 

have falsely claimed to be 

certified under the EUU.S. Privacy Shield 

framework. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

FTC Reaches Settlements 

with Four Companies That 

Falsely Claimed Participatio

in the EU-U.S. Privacy 

Shield 

39 In the Matter of 

IDmission LLC, File 

No. 182-3150, Docket 

No. C-4665 (Sept. 27, 

2018) 

Respondents alleged to 

have falsely claimed to be 

certified under the EUU.S. Privacy Shield 

framework. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

FTC Reaches Settlements 

with Four Companies That 

Falsely Claimed Participatio

in the EU-U.S. Privacy 

Shield 

40 In the Matter of 

SmartStart Emp. 

Screening, Inc., File 

No. 182-3154, Docket 

Respondents alleged to 

have falsely claimed to be 

certified under the EUU.S. Privacy Shield 

framework. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

FTC Reaches Settlements 

with Four Companies That 

Falsely Claimed Participatio

in the EU-U.S. Privacy 

Shield 

FEDERAL TRADE COMMISSION • FTC.GOV 71
No. C-4666 (Sept. 27, 

2018) 

41 FTC v. Apartment 

Hunters, Inc., No.

8:18-CV-1636 (C.D. 

Cal. Sept. 11, 2018) 

(also d/b/a 

Wetakesection8.com) 

Defendants made false or 

unsubstantiated claims in 

the marketing of online 

rental listings offered 

through their websites, 

targeting low-income 

families, elderly, and 

disabled persons. 

Pursuant to a litigated 

final judgment and order, 

Defendants were ordered 

to pay more than $6 

million and permanently 

banned from offering 

rental listing services. 

Defendant UAB 

Apartment Hunters LT is a 

Lithuania company. 

Court Temporarily Halts 

Operators of Rental Listing 

Websites from Making False 

Claims About the 

Availability of Apartments 

That Accept Section 8 

Vouchers and Other Rental 

Properties 

42 In the Matter of BLU 

Products, Inc., File No. 

172-3025, Docket No. 

C-4657 (Sept. 6, 

2018) 

Respondents alleged to 

have allowed a Chinabased third-party service 

provider to collect detailed 

personal information 

about consumers, such as 

text message contents and 

real-time location 

information, without their 

knowledge or consent 

despite promises by the 

company that it would 

keep such information 

secure and private. 

Data transmitted to 

Chinese third party 

without consent or 

notice. 

Mobile Phone Maker BLU 

Reaches Settlement with 

FTC over Deceptive Privacy 

and Data Security Claims 

FEDERAL TRADE COMMISSION • FTC.GOV 72
As part of a settlement, 

respondents are prohibited 

from misrepresenting the 

extent to which they 

protect the privacy and 

security of personal 

information, and BLU will 

be subject to third-party 

assessments of its security 

program for 20 years. 

43 In the Matter of 

ReadyTech Corp., File 

No. 182-3100, Docket 

No. C-4659 (July 2, 

2018) 

Respondent alleged to 

have falsely claimed that it 

was in the process of 

certifying its compliance 

under the EU-U.S. Privacy 

Shield framework. 

As part of a settlement, the 

company is prohibited 

from misrepresenting its 

participation in any 

privacy or security 

program sponsored by a 

government or any selfregulatory or standardsetting organization, 

including the EU-U.S. 

Privacy Shield framework 

and the Swiss-U.S. 

Privacy Shield 

framework. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

California Company Settles 

FTC Charges Related to 

Privacy Shield Participation 

FEDERAL TRADE COMMISSION • FTC.GOV 73
44 FTC v. Triangle Media 

Corp., No.18cv1388-

MMA (NLS) (S.D. 

Cal. June 25, 2018) 

(complaint amended 

Dec. 11, 2018) 

Defendants, who marketed 

and sold various products 

online to consumers in the 

United States, such as skin 

creams, e-cigarettes, and 

dietary supplements, were 

alleged to have 

deceptively advertised 

“risk-free” trial offers and 

enrolled consumers in 

expensive continuity plans 

without their knowledge 

or consent. 

Pursuant to settlements, 

the defendants are barred 

from misrepresenting any 

material facts about a 

negative option 

transaction, must comply 

with the Restore Online 

Shoppers’ Confidence Act 

(ROSCA), and turn over 

more than $9 million in 

assets. 

One of the principal

defendants, Hardwire Inc., 

was a British Virgin 

Islands 

company. Defendant 

Global Northern Trading 

Limited was a Canadian 

company. Defendants 

Hardwire Interactive, 

Global Northern Trading, 

and Devin Keer helped to 

operate the scheme from 

outside the United States. 

Online Marketers Barred 

from Deceptive “Free Trial” 

Offers, Unauthorized Billing

45 FTC v. 9140-9201 

Quebec Inc., No. 1: l 8-

cv-04115 (N.D. Ill. 

June 13, 2018) (a/k/a 

Premium Business 

Pages, Inc.) 

Defendants, based in 

Canada and the United 

States, made unsolicited 

calls to small businesses 

and other organizations to 

induce them to pay for 

unordered internet 

directory listings, search 

engine optimization 

Canadian-based 

defendants targeted 

consumers in the United 

States. The FTC also 

received assistance from 

the Canada Competition 

Bureau. 

FTC, BBB, and Law 

Enforcement Partners 

Announce Results of 

Operation Main Street: 

Stopping Small Business 

Scams Law Enforcement and 

Education Initiative 

FEDERAL TRADE COMMISSION • FTC.GOV 74
services, or website design 

and hosting services. 

The court ordered 

defendants to pay more 

than $4.6 million and 

permanently banned them 

from advertising, 

marketing, or selling any 

directory listings, search 

engine optimization 

services, or website design 

and hosting services. 

46 FTC v. MOBE Ltd., 

No. 6:18-cv-862-Orl37DCI (M.D. Fla. June 

4, 2018) 

Defendants, operators of 

an international 

organization that targeted 

U.S. consumers through 

online ads, social media, 

direct mailers, and live 

events, were alleged to 

have falsely claimed that 

their business education 

program called MOBE 

(“My Online Business 

Education”) would help 

consumers start their own 

business and earn 

substantial income, taking 

in more than $125 million 

from thousands of 

consumers. 

Key perpetrators of the 

scheme Defendants agreed 

to pay more than $17 

Defendants included 

foreign companies from 

Canada, the U.K., 

Panama, Mauritius, and 

Australia. 

FTC Action Halts MOBE, a 

Massive Internet Business 

Coaching Scheme 

FEDERAL TRADE COMMISSION • FTC.GOV 75
million as part of 

settlements with the FTC.

47 FTC v. Next-Gen, Inc., 

No. 4:18-cv-0128

(W.D. Mo. Feb. 20, 

2018) 

Defendants were alleged 

to have operated a 

sweepstake that deceived 

millions of consumers in 

the United States and 

other countries by enticing 

them to pay money to 

collect prizes that never 

materialized. 

Pursuant to a settlement, 

Defendants agreed to 

forfeit a record $30 

million in cash and assets 

and be permanently 

banned from the prize 

promotion business. 

Defendants sent tens of 

millions of deceptive 

personalized mailers to 

consumers around the 

world, including in 

Canada, the United 

Kingdom, France, and 

Germany. 

FTC Challenges Schemes 

That Target or Affect Senior 

Citizens 

48 FTC v. Digit. Altitude 

LLC, No. 18-cv-00729 

(C.D. Cal. Jan. 29, 

2018). 

Defendants alleged to 

have operated a multimillion-dollar business 

coaching scheme that 

deceived consumers by 

claiming they could earn 

"six figures in 90 days." 

As part of settlement 

orders, certain former 

officers of the scheme are 

permanently banned from 

selling businesses 

Three corporate 

defendants were foreign 

(U.K.) companies 

operating in the United 

States. 

FTC Obtains Court Order 

Halting Business Coaching 

Scheme 

FEDERAL TRADE COMMISSION • FTC.GOV 76
coaching or investment 

opportunity services. 

49 FTC v. Emp Media, 

Inc., also d/b/a 

Myex.com, No. 2:18-

cv-00035 (D. Nev. Jan. 

9, 2018) 

Defendants, operators of a 

revenge porn website, 

alleged to have posted 

intimate pictures of people 

along with their personal 

information without their 

consent. 

Defendants ordered to 

destroy all intimate images 

and personal information 

in their possession, to shut 

down the website 

permanently, and pay 

more than $2 million. 

Principal defendant 

Cottelli had substantial 

connection to South 

Africa, and routinely 

travelled to South Africa 

and the Philippines. The 

FTC made extensive 

efforts to serve him 

domestically and abroad, 

receiving assistance from 

authorities in the U.K. 

about his possible 

whereabouts in London, 

before the court allowed 

the FTC to serve him via 

email. 

FTC and Nevada Seek to 

Halt Revenge Porn Site 

50 U.S. v. VTech Elecs. 

Ltd, No. 1:18-cv-00114 

(N.D. Ill. Jan. 8, 2018)

Defendants alleged to 

have violated COPPA by 

collecting personal 

information from children 

without providing direct 

notice to and obtaining 

consent from parents and 

failing to take reasonable 

steps to secure the data it 

collected. 

As part of a settlement, 

VTech agreed to pay 

$650,000. 

The FTC collaborated 

with the Office of the 

Privacy Commissioner of 

Canada (OPC), which 

released its own Report of 

Findings. To facilitate 

cooperation with OPC, the 

FTC relied on the U.S. 

SAFE WEB Act. 

Electronic Toy Maker VTech 

Settles FTC Allegations Tha

it Violated Children’s 

Privacy Law and the FTC 

Act 

FEDERAL TRADE COMMISSION • FTC.GOV 77
2017

51 FTC v. Montano, 6:17-

CV-2203-JA-KRS 

(M.D. Fla. Dec. 28, 

2017) 

Defendants alleged to 

have operated a get-richquick scheme bilking 

consumers out of millions 

of dollars by falsely 

promising consumers they 

could earn hundreds to 

thousands of dollars a day 

using the defendants’ 

Mobile Money Code 

products. 

As part of a settlement, 

defendants agreed to a $7 

million judgment and a 

permanent ban on 

marketing or selling 

certain types of software. 

Defendant Martin Schranz 

is an Austrian citizen who 

resides in Switzerland; 

defendant GSD Master 

AG is a Swiss company. 

FTC Alleges Get-Rich-Quick 

Scheme Bilked Consumers 

out of Millions with 

Deceptive Claims 

52 FTC v. A1 Janitorial 

Supply Corp., No. 

1:17-cv-07790 (N.D. 

Ill, Oct. 30, 2017) 

Defendants alleged to 

have called small 

businesses throughout the 

United States and Canada, 

offered a free sample, and 

then billed them for it, 

even when they refused 

the sample. 

A settlement imposes a 

$2.7 million judgment 

against the defendants. 

Defendants marketed and 

sold products in Canada. 

FTC Charges Office Supply 

Scheme with Bilking 

Millions of Dollars from 

Small Businesses for ‘Free’ 

Samples of Cleaning 

Products 

FEDERAL TRADE COMMISSION • FTC.GOV 78
53 In the Matter of 

Decusoft, LLC, File 

No. 172-3173, Docket 

No. C-4630 (Sept. 8, 

2017) 

Respondent alleged to 

have falsely claimed 

participation in the EUU.S. Privacy Shield 

framework. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

Three Companies Agree to 

Settle FTC Charges They 

Falsely Claimed Participatio

in EU-US Privacy Shield 

Framework 

54 In the Matter of Tru 

Commc’n, Inc., File 

No. 172-3171, Docket 

No. C-4628 (Sept. 8, 

2017) 

Respondent alleged to 

have falsely claimed 

participation in the EUU.S. Privacy Shield 

framework. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

Three Companies Agree to 

Settle FTC Charges They 

Falsely Claimed Participatio

in EU-US Privacy Shield 

Framework 

55 In the Matter of Md7, 

LLC, File No. 172-

3172, Docket No. C4629 (Sept. 8, 2017) 

Respondent alleged to 

have falsely claimed 

participation in the EUU.S. Privacy Shield 

framework. 

Data transfers under the 

EU-U.S. Privacy Shield 

framework. 

Three Companies Agree to 

Settle FTC Charges They 

Falsely Claimed Participatio

in EU-US Privacy Shield 

Framework 

56 FTC v. Bob Robinson, 

LLC, No. 17 CV 2411 

(S.D. Tex. Aug. 7, 

2017) 

Defendants alleged to 

have operated a scheme to 

lure consumers into 

buying an online system, 

falsely promising they 

would earn thousands of 

dollars working from 

home. 

As part of a settlement, a 

$35.1 million judgment 

was imposed on the 

defendants. 

Defendant Mega Export 

2005 (Mega Canada) is a 

Canadian corporation. 

FTC Obtains Temporary 

Restraining Order Halting 

Work-at-Home Scheme 

57 FTC v. Vylah Tec LLC, 

No. 2:17-cv-228-FtMDefendants alleged to have caused consumers’ 

N/A FTC and Federal, State and 

International Partners 

FEDERAL TRADE COMMISSION • FTC.GOV 79
99MRM (M.D. Fla. 

May 1, 2017) 

computers to appear as if 

they were infected with 

viruses, were being 

hacked, or otherwise 

compromised and then 

represented themselves as 

agents of Microsoft or 

other technology 

companies to persuade 

consumers to pay 

hundreds of dollars for 

tech support services. 

Announce Major Crackdown 

on Tech Support Scams

(May 12, 2017) 

58 FTC v. Repair All PC, 

LLC. No. 1:17-cv-0869 

(N.D. Ohio Apr. 24, 

2017) 

Defendants alleged to 

have caused consumers’ 

computers to appear as if 

they were infected with 

viruses, were being 

hacked, or otherwise 

compromised and then 

represented themselves as 

agents of Microsoft or 

other technology 

companies to persuade

consumers to pay 

hundreds of dollars for 

tech support services. 

Settlement imposed a 

$12.4 million judgment 

and barred defendants 

from offering tech support 

products and services. 

Defendant, I Fix PC, is a 

Canadian business. 

Investigation included 

cooperation with 

international law 

enforcement partners. 

FTC and Federal, State and 

International Partners 

Announce Major Crackdown 

on Tech Support Scams 

59 In the Matter of 

SpyChatter, Inc., File 

Respondent alleged to 

have deceived consumers 

Data transfers under the 

Asia-Pacific Economic 

Three Companies Settle FTC 

Charges that They Deceived 

FEDERAL TRADE COMMISSION • FTC.GOV 80
No. 162-3251, Docket 

No. C-4614 (Feb. 22, 

2017) 

about their participation in 

the Asia-Pacific Economic 

Cooperation (APEC) 

Cross-Border Privacy 

Rules (CBPR) system. 

Cooperation (APEC) 

Cross-Border Privacy 

Rules (CBPR) system. 

Consumers About 

Participation in International 

Privacy Program 

60 In the Matter of 

Sentinel Labs, Inc., File 

No.162- 3250, Docket 

No. C-4608 (Feb. 22, 

2017) 

Respondent alleged to 

have made deceptive 

statements that they 

participated in the APEC 

CBPR and falsely claimed 

that it was a participant in 

a TRUSTe privacy 

program. 

Data transfers under the 

Asia-Pacific Economic 

Cooperation (APEC) 

Cross-Border Privacy 

Rules (CBPR) system. 

Three Companies Settle FTC 

Charges that They Deceived 

Consumers About 

Participation in International 

Privacy Program 

61 In the Matter of Vir2us, 

Inc., File No. 162-

3248, Docket No. C4609 (Feb. 22, 2017) 

Respondent alleged to 

have made deceptive 

statements that they 

participated in the APEC 

CBPR. 

Data transfers under the 

Asia-Pacific Economic 

Cooperation (APEC) 

Cross-Border Privacy 

Rules (CBPR) system. 

Three Companies Settle FTC 

Charges that They Deceived 

Consumers About 

Participation in International 

Privacy Program 

62 FTC v. PHLG Enters., 

LLC., No. 8:17-cv00220-RAL-AEP 

(M.D. Fla. Jan. 27, 

2017) 

Defendants alleged to 

have helped telemarketers 

in India deceive American 

consumers into paying 

hundreds or thousands of 

dollars for taxes they did 

not owe, or fees for 

services they did not 

receive. 

As part of a settlement, a 

$1.5 million monetary 

judgment was imposed on 

defendants. 

The defendants and their 

runners kept a portion of 

the money and delivered 

the rest to India-based 

scammers through a 

complex series of 

transactions designed to 

avoid detection by law 

enforcement. 

FTC Settlement Puts a Stop 

to Money Mule Who Profite

from India-Based IRS and 

Other Scams 

FEDERAL TRADE COMMISSION • FTC.GOV 81
63 FTC v. Western Union 

Co., No. 1:17-cv00110-CCC (M.D. Pa. 

Jan. 19, 2017) 

Defendant alleged to have 

willfully failed to maintain 

an effective anti-money 

laundering program and 

aided and abetted wire 

fraud. 

Defendant agreed to a 

monetary judgment of 

$586 million. 

Case involved assets sent 

abroad, with international 

as well as U.S. victims, 

and significant 

international cooperation, 

including from the 

Toronto Police Service, 

Canadian Anti-Fraud 

Centre, Royal Canadian 

Mounted Police and 

Spanish National 

Police. 

Western Union Admits AntiMoney Laundering 

Violations and Settles 

Consumer Fraud Charges, 

Forfeits $586 Million in 

Settlement with FTC and 

Justice Department 

64 FTC v. D-Link Corp.,

No. 3:17-cv-00039

(N.D. Ill. Jan. 5, 

2017) 

Defendants alleged to 

have inadequately 

maintained proper security 

for its wireless routers and 

internet cameras. 

As part of a settlement, 

defendant D-Link was 

required to implement a 

comprehensive software 

security program and 

obtain biennial, 

independent, third-party 

assessments of its software 

The FTC’s initial 

complaint named the 

Taiwanese parent of DLink. 

FTC Charges D-Link Put 

Consumers’ Privacy at Risk 

Due to the Inadequate 

Security of Its Computer 

Routers and Cameras 

FEDERAL TRADE COMMISSION • FTC.GOV 82
security program for 10 

years. 

2016

65 FTC v. Ruby Corp., 

also doing business as 

AshleyMadison.com, 

No. 1:16-cv-02438 

(D.D.C. Dec. 14. 

2016) 

Defendants, operators of a 

dating website, were 

alleged to have used fake 

profiles to entice 

customers to pay for 

memberships and failed to 

protect 36 million users’ 

account and profile 

information in relation to a 

massive July 2015 data 

breach of their network. 

A $8.75 million judgment 

was imposed on the 

defendants as part of 

settlement. 

Principal defendant was a 

Canadian corporation. 

Investigation involved 

cooperation with Canadian 

and Australian Privacy 

Commissioners. 

Defendant’s website, 

AshleyMadison.com, had 

members from over 46 

countries. 

Operators of 

AshleyMadison.com Settle 

FTC, State Charges 

Resulting From 2015 Data 

Breach that Exposed 36 

Million Users’ Profile 

Information 

66 FTC v. Glob. Access 

Tech. Support LLC, 

No. 4:16-cv-01556-

HEA (E.D. Mo. Oct. 3, 

2016) 

Defendants alleged to 

have operated a multinational tech support 

company which used 

deceptive pop-up internet 

ads to scare thousands of 

consumers into paying 

hundreds of dollars for 

unnecessary technical 

support services. 

As part of a settlement, 

defendants agreed to turn 

over assets valued at more 

India-based defendant and 

call center. 

FTC Charges Tech Support 

Companies With Using 

Deceptive Pop-Up Ads to 

Scare Consumers Into 

Purchasing Unneeded 

Services 

FEDERAL TRADE COMMISSION • FTC.GOV 83
than $1 million and were 

banned from marketing or 

promoting any technical 

support products or 

services. 

67 FTC v. Somenzi, No. 

2:16-cv-07101, (C.D. 

Cal. Sept. 21, 2016) 

Defendants used 

international mail network 

to operate a fake prize 

scam. 

As part of a settlement, a 

$800,000 judgment was 

imposed against defendant 

Ian Gamberg. A judgment 

also ordered defendants 

Raff and Millenium Direct 

were required to pay 

$501,895 and banned 

them from the prize 

promotion business. 

Case brought as part of an 

international initiative 

targeting mass mail fraud 

and involved cooperation 

with foreign counterpart 

agencies. 

FTC Charges Fake Prize 

Scheme Operators with 

Fraud 

68 FTC v. OMICS Grp. 

Inc., No. 2:16-cv02022 (D. Nev. Aug. 

25, 2016) 

Defendants, online 

publishers of hundreds of 

purported academic 

journals, deceived 

academics and researchers 

about the nature of its 

publications and hid 

publication fees ranging 

from hundreds to 

thousands of dollars. 

A judgment of $50.1 

million judgment was 

India-based defendants. FTC Charges Academic 

Journal Publisher OMICS 

Group Deceived Researchers

FEDERAL TRADE COMMISSION • FTC.GOV 84
imposed against the 

defendants. 

69 FTC v. Big Dog Sol. 

LLC, also d/b/a Help 

Desk National, No. 

1:16-cv-06607 (N.D. 

Ill, June 24, 2016) 

Defendants ran an 

international tech support 

scam duping victims into 

paying hundreds of dollars 

for dubious computer 

“repairs” and antivirus 

software. 

Nearly $10 million 

monetary judgment 

entered against defendants 

as part of settlement. 

Several defendants based 

in Canada. This matter 

was also part of a 

coordinated effort with 

international partners to 

crackdown on tech 

support scams which 

included working with 

authorities in India. 

FTC and Florida Charge 

Tech Support Operation with 

Tricking Consumers Into 

Paying Millions for Bogus 

Services 

70 U.S. v. InMobi Pte Ltd., 

No. 3:16-cv-3474 

(N.D. Cal. June 22, 

2016) 

Defendant, operator of a 

mobile advertising 

network, alleged to have 

deceptively tracked the 

locations of hundreds of 

millions of consumers – 

including children – 

without their knowledge 

or consent to serve them 

geo-targeted advertising. 

As part of settlement, 

defendant was subject to a 

$4 million civil penalty 

and defendant was 

required to delete all 

information it collected 

from children. 

Singapore-based 

defendant. 

Mobile Advertising Network 

InMobi Settles FTC Charges 

It Tracked Hundreds of 

Millions of Consumers’ 

Locations Without 

Permission 

FEDERAL TRADE COMMISSION • FTC.GOV 85
71 In the Matter of Very 

Incognito Techs., Inc.,

also d/b/a Vipvape, 

File No. 162-3034, 

Docket No. C-4580 

(May 4, 2016) 

Respondent alleged to 

have Deceived consumers 

about its participation in 

the APEC CBPR system. 

Data transfers under the 

APEC CBPR system. 

Hand-Held Vaporizer 

Company Settles FTC 

Charges It Deceived 

Consumers About 

Participation in International 

Privacy Program 

72 In the Matter of 

ASUSTek Comput., 

Inc., File No. 142-

3156, Docket No. C4587 (Feb. 23, 2016) 

Respondent alleged to 

have critical security flaws 

in its routers put home 

networks of hundreds of 

thousands of consumers at 

risk and routers’ insecure 

“cloud” services led to the 

compromise of thousands 

of consumers’ connected 

storage devices, exposing 

their sensitive personal 

information on the 

internet. 

Defendant required to 

establish and maintain a 

comprehensive security 

program subject to 

independent audits for the 

next 20 years as part of a 

settlement. 

Taiwan-based defendant. ASUS Settles FTC Charges 

That Insecure Home Routers 

and “Cloud” Services Put 

Consumers’ Privacy At Risk

73 FTC v. Stratford 

Career Inst., Inc., No. 

1:16-cv-00371 (N.D. 

Ohio Feb. 18, 2016) 

Defendant alleged to have 

misled consumers about 

its online high school 

equivalency program that 

failed to meet the basic 

Defendant based in 

Quebec, Canada. 

FTC Files Action Against 

Stratford Career Institute for 

Misleading Consumers 

FEDERAL TRADE COMMISSION • FTC.GOV 86
requirements set by most 

states. 

Settlement imposed a $6.5 

million judgment against 

the defendant and 

defendant was required to 

notify its current students 

of their right to cancel 

enrollment in the high 

school diploma program. 

About Online High School 

‘Diploma’ Course 

2015

74 FTC v. Click4Support, 

LLC, No. 2:15-cv05777-SD (E.D. Pa. 

Oct. 26, 2015) 

Defendants alleged to 

have run a tech support 

scam that bilked 

consumers out of more 

than $17 million by 

pretending to represent 

Microsoft, Apple and 

other major tech 

companies. 

As part of settlement, 

defendants are banned 

from marketing technical 

support services and 

ordered to pay more than 

$554,000 and forfeit $1.3 

million. 

Amended complaint added 

an India-based 

defendants. 

FTC, Pennsylvania and 

Connecticut Sue Tech 

Support Scammers That 

Took More Than $17 Million 

From Consumers 

75 In the Matter of Am. 

Int’l Mailing, Inc., File 

No. 152-3051, Docket 

Respondent alleged to 

have falsely claimed that 

they were currently 

certified under the U.S.-

Data transfers under the 

U.S.-EU Safe Harbor 

Privacy Framework and 

FTC Settles with Two 

Companies Falsely Claiming 

to Comply with Internationa

FEDERAL TRADE COMMISSION • FTC.GOV 87
No. C-4526 (May 20,

2015) 

EU Safe Harbor Privacy 

Framework and U.S.-

Swiss Safe Harbor Privacy 

Framework, when in fact 

their certifications had 

lapsed years earlier. 

U.S.-Swiss Safe Harbor 

Privacy Framework. 

Safe Harbor Privacy 

Framework 

76 In the Matter of TES 

Franchising, LLC, File 

No. 152-3015, Docket 

No. C-4525 (May 20, 

2015) 

Respondent alleged to 

have falsely claimed that 

they were currently 

certified under the U.S.-

EU Safe Harbor Privacy 

Framework and U.S.-

Swiss Safe Harbor Privacy 

Framework, when in fact 

their certifications had 

lapsed years earlier. 

Data transfers under the 

U.S.-EU Safe Harbor 

Privacy Framework and 

U.S.-Swiss Safe Harbor 

Framework. 

 

FTC Settles with Two 

Companies Falsely Claiming 

to Comply with Internationa

Safe Harbor Privacy 

Framework 

77 FTC v. Mail Tree Inc., 

No. 0:15-cv-61034-JIC 

(S.D. Fla. May 18, 

2015) 

Defendants alleged to 

have conducted a 

fraudulent sweepstakes 

scam, by mailing 

personalized letters 

soliciting payments of 

$20-$30 in exchange for 

false large cash awards of 

typically, more than $2 

million. 

Global scam with victims 

located in Australia, 

Canada, France, Germany, 

Japan, and the U.K. 

Enforcement cooperation 

with the Vancouver Police 

Department, the Windsor 

(Ontario) Police Service, 

and the Metropolitan 

Police in the United 

Kingdom. 

FTC Action Halts Global 

Sweepstakes Scam 

78 FTC v. Coorga 

Nutraceuticals Corp., 

No 15-CV-72-S (D. 

Wyo. May 13, 2015) 

Defendants made 

unfounded claims that 

their products could 

prevent or reverse gray 

hair. 

Defendant Coore claimed 

that two products were 

approved by Health 

Canada. 

FTC Challenges Marketers’ 

Baseless Claims That Their 

Supplements Prevent or 

Reverse Gray Hair 

FEDERAL TRADE COMMISSION • FTC.GOV 88
Defendants ordered to pay 

$391,335 as part of 

summary judgment 

against them. 

79 FTC v. DIRECTV, No. 

3:15-cv-01129 (N.D. 

Cal. Mar. 11, 2015) 

Defendants alleged to 

have made misleading 

representations about 

pricing for direct-to-home 

digital television services.

FTC moved for an order 

to serve a deposition 

subpoena on a witness in 

Spain. 

FTC Charges DIRECTV 

with Deceptively Advertising 

the Cost of Its Satellite 

Television Service 

80 FTC v. Am. Yellow 

Browser, Inc., No. 15-

CV-2047 (N.D. 

Ill. Mar. 9, 2015) 

(a/k/a Medical Yellow 

Directories, Inc.) 

Defendants defrauded 

medical practices, 

churches, and retirement 

homes by running a 

business directory scam 

where they misrepresented 

that consumers have 

agreed to buy a business 

directory listing and owe 

them money. 

Defendants were banned 

from the directory 

business and ordered to 

pay more than $1.2 

million. 

Three defendants were 

based in Montreal, 

Canada. 

FTC Halts Online ‘Yellow 

Pages’ Scammers 

81 FTC v. Lasarow, No. 

1:15-cv-01614 (E.D. 

Ill. Feb. 23, 2015) 

(a/k/a Mole Detective)

Defendants alleged to 

have made deceptive 

claims that their mobile 

apps could detect 

symptoms of melanoma. 

Defendant L Health Ltd. is 

a U.K. company. 

FTC Cracks Down on 

Marketers of “Melanoma 

Detection” Apps 

2014

FEDERAL TRADE COMMISSION • FTC.GOV 89
82 In the Matter of True 

Ultimate Standards 

Everywhere, Inc., also 

d/b/a TRUSTEe, Inc.,

File No. 132-3219, 

Docket No. C-4512 

(Nov. 17, 2014) 

Respondents alleged to 

have deceived consumers 

about its recertification 

program, which provides 

seals to businesses that 

meet specific requirements 

for consumer privacy 

programs such as COPPA

and the U.S.-EU Safe 

Harbor Privacy 

Framework. 

Defendants required to 

pay $200,000 as part of 

settlement. 

Data transfers under the 

U.S.-EU Safe Harbor 

Framework. 

TRUSTe Settles FTC 

Charges it Deceived 

Consumers Through Its 

Privacy Seal Program 

83 FTC v. Diversified 

Educ. Res., LLC, also 

d/b/a Jefferson High 

School Online, No. 

0:14-cv-62116-JIC 

(S.D. Fla. Sept. 16, 

2014) 

Defendants alleged to 

have marketed and sold 

fake high school diplomas 

online and fabricated an 

accrediting body to give 

legitimacy to the diploma 

mill operation. 

Foreign defendants based 

in Mexico and St. Kitts 

and Nevis. 

FTC Action Halts Online 

High School Diploma Mill 

That Made $11 Million 

Selling Worthless Diplomas 

to Students 

84 FTC v. CWB Servs., 

No. 4:14-cv-00783-

DW (W.D. Mo. Sept. 

5, 2014) 

Defendants alleged to 

have bilked consumers out 

of tens of millions of 

dollars by trapping them 

into payday loans they 

never authorized and then 

using the supposed 

“loans” as a pretext to take 

money from their bank 

accounts. 

Defendant Sandpoint 

Capital LLC was a Nevisbased company. 

FTC Action Halts Payday 

Loan Scheme That Bilked 

Tens of Millions From 

Consumers By Trapping 

Them Into Supposed “Loans

They Never Authorized 

FEDERAL TRADE COMMISSION • FTC.GOV 90
Judgments of $32 million 

and $22 million imposed 

against defendants, 

Coppinger and his 

companies and Rowland 

and his companies, 

respectively as part of 

settlement. 

85 FTC v. OnlineYellow 

PagesToday.com, Inc., 

No. 2:14-cv-00838-

RAJ (W.D. Wash. June 

9, 2014) 

Defendants alleged to 

have defrauded millions of 

dollars from businesses, 

churches, nonprofits and 

local governments by 

charging them for 

unwanted listings in online 

“yellow pages” 

directories. 

As part of settlement, a 

$3,081,969 monetary 

judgment was imposed on 

the defendants. 

Multiple Canadian 

defendants. 

FTC and Florida Halt 

Internet ‘Yellow Pages’ 

Scammers 

86 FTC v. 7051620 

Canada, Inc., No. 1:14-

CV-22132-FAM (S.D. 

Fla. June 9, 2014) 

Defendants alleged to 

have defrauded millions of 

dollars from small 

businesses, churches, 

nonprofits and local 

government agencies by 

charging them for 

unwanted listings in online 

“yellow pages” 

directories. 

Defendant 7051620 

Canada, Inc. is a Canadian 

corporation. 

FTC and Florida Halt 

Internet ‘Yellow Pages’ 

Scammers 

FEDERAL TRADE COMMISSION • FTC.GOV 91
As part of settlement, 

defendants were ordered 

to pay $1.7 million. 

87 FTC v. First 

Consumers, LLC, No. 

14-1608 (E.D. Pa. Mar. 

18, 2014) 

Defendants alleged to 

have impersonated 

government and bank 

officials to defraud 

consumers of their bank 

account information. The 

defendants used that 

information to create 

checks drawn on 

consumers’ bank accounts 

and then deposit the 

“remotely created checks” 

into corporate accounts 

established in the United 

States before transferring 

the money to accounts 

controlled by Canadian 

defendants. 

Settlement agreements 

with defendants Ferry and 

Barczi imposed judgments 

of $9,655,638 and 

$325,449 respectively. 

Summary judgment 

entered against Ari 

Tietolman and the 

corporate entities imposed 

a judgment of $10.7 

million. 

Canadian defendants. FTC Stops Mass 

Telemarketing Scam That 

Defrauded U.S. Seniors and 

Others Out of Millions of 

Dollars 

FEDERAL TRADE COMMISSION • FTC.GOV 92
2013

88 FTC v. Loewen, No. 

12-cv-1207 MJP, 

(W.D. Wash. Dec. 2,

2013) (a/k/a Vehicle 

Stars) 

Defendants duped 

consumers into paying 

hundreds of dollars based 

on false claims that the 

defendants had buyers 

lined up for their cars. 

A federal court ordered 

the defendants to pay 

more than $5.1 million 

and banned the defendants 

from telemarketing and 

payment processing. 

The defendants are 

Loewen, a Canadian 

telemarketer, and the four 

companies he owns. 

American and Canadian 

consumers were harmed 

by the telemarketing 

scheme. The FTC received 

assistance of Business 

Practices and Consumer 

Protection Authority, 

British Columbia, 

Canada. 

At FTC's Request, 

Telemarketer Ordered to Pay 

$5.1 Million to Reimburse 

Victims of Car-Buying 

Scam 

89 FTC v. Mod. Tech. 

Inc., also d/b/a Online 

Local Yellow Pages,

No. 13cv8257, (N.D. 

Ill. Nov. 18, 2013) 

Defendants bilked 

millions of dollars from 

small businesses and 

churches by charging them 

for unwanted listings in 

online “yellow pages” 

directories. Defendants 

often bullied consumers 

into paying by threatening 

to sue them or damage 

their credit ratings. 

A judgment of more than 

$15.6 million was entered 

against the defendants. 

The company and 

defendant Kaddoura 

operated out of Montreal, 

Canada, using shell 

companies and mail drops 

in the United States to 

hide their location. The 

FTC obtained cooperation 

from the Canadian AntiFraud Centre, the 

Kahnawake Mohawk 

Peacekeepers, Royal 

Canadian Mounted Police 

and the Centre of 

Operations Linked to 

Telemarketing Fraud. 

FTC Stops Online 'Yellow 

Pages' Scam; Canada-Based 

Operation Targeted Small 

Businesses and Churches in 

United States 

90 FTC v. Applied Mktg. 

Scis., LLC, No. CV13-

06794 CAS (CWX), 

Defendants alleged to 

have operated a 

sweepstakes scam that 

Defendants sent nearly 

800,000 letters to 

consumers in 156 

FTC Sues to Stop Massive 

Sweepstakes Scam 

FEDERAL TRADE COMMISSION • FTC.GOV 93
(C.D. Cal. Sept. 16, 

2013) 

took more than $11 

million from consumers 

by mass mailing 

personalized letters to 

millions of consumers and 

fraudulently telling them 

that they had won a large 

cash prize, typically more 

than $2 million, in 

exchange for a fee of $20 

to $30. 

As part of a settlement, 

defendants were banned 

from any conduct 

involving prize 

promotions and a 

judgment of more than 

$11 million was imposed.

countries around the 

world. The FTC obtained 

cooperation from the 

Vancouver Police 

Department, the 

Metropolitan Police in the 

U.K, the National Fraud 

Intelligence Bureau, and 

the Australian 

Competition 

and Consumer 

Commission. 

91 FTC v. AFD Advisors, 

LLC, No. 13-cv-6420 

(N.D. Ill. Sept. 9, 

2013) 

Defendants alleged to 

have operated a medical 

discount telemarketing 

scheme that scammed 

seniors by convincing 

them to give over their 

bank account information 

to continue receiving their 

Medicare, Social Security, 

or other insurance 

benefits. Defendants 

alleged to have used the 

victims’ bank account 

information to debit 

Numerous defendants 

were Canadian 

corporations or owners of 

those Canadian 

corporations. The FTC 

received assistance from 

the Canadian Anti-Fraud 

Centre; Royal Canadian 

Mounted Police; and the 

Centre of Operations 

Linked to Telemarketing 

Fraud. 

FTC Cracks Down On Bogu

Medical Discount Scam 

Targeting Seniors 

FEDERAL TRADE COMMISSION • FTC.GOV 94
money from victims’ 

accounts. 

As part of settlement, a 

judgment over $1 million 

was imposed on certain 

defendants. A monetary 

judgment of nearly 

$900,000 was entered 

against other defendants. 

92 FTC v. Money Now 

Funding, LLC., No. 

CV-13-01583-PHXROS, (D. Ariz., Aug. 5, 

2013) 

Defendants alleged to 

have falsely promised 

consumers that they could 

make money by referring 

merchants in their area to 

the defendants’ nonexistent money-lending 

service. 

Various judgments against 

and settlements with the 

18 defendants imposed a 

ban on selling business or 

work-at-home 

opportunities and imposed 

a monetary judgment of 

$7.3 million against 12 

defendants and smaller 

judgments against the 

others. 

Defendants have marketed 

and sold home-based 

business opportunities to 

consumers throughout the 

United States and 

Canada. 

FTC Halts Elusive Business 

Opportunity Scheme 

93 FTC v. Vacation 

Commc’ns Grp., LLC., 

6:13-cv-00789-RBDDefendants alleged to 

have operated a fraudulent 

timeshare resale scam 

where timeshare owners 

Defendant Cohen 

conducted business from 

FTC and Dozens of Law 

Enforcement Partners Halt 

Travel and Timeshare Resale 

FEDERAL TRADE COMMISSION • FTC.GOV 95
DAB (M.D. Fla. May 

20, 2013) 

were tricked into paying 

up-front fees based on 

claims that interested 

buyers ready to pay top 

dollar for the properties. 

Monetary judgment of 

over $10 million imposed 

on defendants Cohen and 

his company Vacation 

Communications Group 

LLC. 

the Dominican 

Republic. 

Scams in Multinational 

Effort 

94 FTC v. Construct Data 

Publishers, a.s. d/b/a 

Fair Guide, No. 13-

CV-1999, (N.D. Ill. 

Mar. 14, 2013) 

Defendants alleged to 

have tricked small 

businesses and non-profits 

into collectively paying 

millions of dollars to be 

listed in an online 

directory in which they 

had no interest in being 

listed and for which they 

did not understand they 

would be charged. 

Defendant Construct Data 

Publishers a.s. is a foreign 

business operating out of 

Slovakia. Individual 

defendants Valdova and 

Anhorn were foreign 

defendants also based in 

Slovakia. The FTC 

obtained cooperation from 

the Ministry of Justice of 

the Republic of Slovakia, 

the Slovak Police Attaché, 

and the Ministry of Justice 

of Austria. 

FTC Stops Foreign Operatio

That Scammed Many Small 

Businesses and Nonprofits 

Into Paying Millions of 

Dollars for Bogus Online 

Directory 

2012

95 FTC v. E.M.A 

Nationwide, Inc., d/b/a 

EMA and Expense 

Mgmt. of Am., No. 

1:12-cv-02394-JG 

Defendants alleged to 

have deceived consumers 

through a telemarketing 

scheme designed to sell 

them phony mortgage 

The matter included 

multiple Canadian 

defendants. The FTC also 

received cooperation from 

Canada law enforcement 

agencies including the 

FTC Cracks Down on Phony 

Mortgage Relief Schemes 

FEDERAL TRADE COMMISSION • FTC.GOV 96
(N.D. Ohio Sept. 25, 

2012) 

assistance and debt relief 

programs. 

Court order permanently 

bars the defendants from 

working in the debt relief 

or mortgage assistance 

industries and imposes a 

monetary judgment of 

$5.7 million. 

Royal Canadian Mounted 

Police. 

96 FTC v. Marczak, d/b/a 

Virtual PC Sols., No. 

1:12-cv-07192-PAE 

(S.D. N.Y. Sept. 24, 

2012) 

Defendants alleged to 

have operated a tech 

support scheme. 

Defendants posed as major 

computer security and 

manufacturing companies 

to deceive consumers into 

believing that their 

computers were riddled 

with viruses, spyware, and 

other malware, and then 

charged them hundreds of 

dollars to remotely access 

and fraudulently “fix” the 

computers. 

This matter was part of an 

international crackdown 

on tech support scams 

targeting English 

speakers. 

The matter included an 

India-based defendant. 

The scheme targeted 

English-speaking 

consumers in Canada, 

Australia, Ireland, New 

Zealand, and the U.K. 

FTC Halts Massive Tech 

Support Scams 

97 FTC v. Pecon Software 

Ltd., No. 1:12-cvDefendants alleged to have operated a tech 

support scheme by posing 

The matter included Indiabased defendants. The 

scheme targeted EnglishFTC Halts Massive Tech 

Support Scams 

FEDERAL TRADE COMMISSION • FTC.GOV 97
07186-PAE (S.D. N.Y. 

Sept. 24, 2012) 

as major computer 

security and 

manufacturing companies 

to deceive consumers into 

believing that their 

computers were riddled 

with viruses, spyware and 

other malware. Defendants 

then charged consumers 

hundreds of dollars to 

remotely access and 

fraudulently “fix” the 

computers. 

This matter was part of an 

international crackdown 

on tech support scams 

targeting English 

speakers. 

Defendants ordered to pay 

over $500,000 as part of 

default judgment. 

speaking consumers in 

Canada, Australia, Ireland, 

New Zealand, and the 

U.K. The FTC also 

cooperated with Canada, 

the U.K., and Australia. 

98 FTC v. PCCare 24/7 

Inc., No. 1:12-cv07189-PAE (S.D.N.Y. 

Sept. 24, 2012) 

Defendants alleged to 

have operated a tech 

support scheme, posing as 

major computer security 

and manufacturing 

companies to deceive 

consumers into believing 

that their computers were 

infected with viruses, 

spyware and other 

malware. Defendants then 

charged consumers 

The matter included Indiabased defendants and 

targeted English-speaking 

consumers in Canada, 

Australia, Ireland, New 

Zealand, and the U.K. The 

FTC also cooperated with 

Canada, UK, and 

Australia. 

FTC Halts Massive Tech 

Support Scams 

FEDERAL TRADE COMMISSION • FTC.GOV 98
hundreds of dollars to 

remotely access and 

fraudulently “fix” the 

computers. 

This matter was part of an 

international crackdown 

on tech support scams 

targeting English 

speakers. 

Monetary judgment of 

$2.9 million imposed on 

defendants as part of 

default judgment. 

99 FTC v. Freedom Cos. 

Mktg., Inc., No. 12-cv5743, (N.D. Ill. July 

23, 2012) 

Defendants alleged to 

have peddled fake 

mortgage assistance relief 

to financially distressed 

Spanish-speaking 

homeowners in the United 

States by falsely 

promising to lower 

homeowners’ monthly 

mortgage payments in 

exchange for a hefty 

upfront fee. 

A settlement order bans 

the defendants from 

marketing any mortgage 

assistance relief products 

or services. 

One defendant was 

incorporated and 

headquartered in the 

Dominican Republic. 

FTC Action Halts Dominican 

Mortgage Assistance Scam 

That Allegedly Defrauded 

Spanish-Speaking U.S. 

Homeowners of more than $

Million 

FEDERAL TRADE COMMISSION • FTC.GOV 99
100 FTC v. Am. Credit 

Crunchers, No. 12-cv1028 (E.D. Ill. Feb. 13, 

2012) 

Defendant alleged to have 

worked with bogus debt 

collectors in India to 

deceive and threaten 

consumers into paying 

debts that were not owed 

or that defendants were 

not authorized to collect, 

taking in over $5 million 

over two years. 

A $5.4 million judgment 

was imposed on 

defendants as part of the 

settlement agreement. 

Defendants worked with 

bogus debt collectors in 

India. 

U.S. Defendants Who 

Allegedly Abetted Fake Deb

Collector Calls from India 

Agree to Settle FTC 

Charges 

2011

101 FTC v. Willms, No. 

2:11-cv-00828 (W.D. 

Wash. May 16, 2011) 

Defendants alleged to 

have committed fraud by 

luring consumers into 

“free” or “risk-free” offers 

and then charging them 

for products and services 

they did not want or agree 

to purchase. 

A $359 million judgment 

was imposed on 

defendants as part of 

settlement. 

The FTC worked closely 

with Canadian law 

enforcement, including the 

Alberta Partnership 

Against Cross Border 

Fraud, in investigating this 

international scheme. 

Most of the defendants 

were located in Alberta. 

Victims of scheme of were 

located in United States, 

Canada, the United 

Kingdom, Australia, and 

New Zealand. 

FTC Charges Online 

Marketers with Scamming 

Consumers out of Hundreds 

of Millions of Dollars with 

'Free' Trial Offers 

FEDERAL TRADE COMMISSION • FTC.GOV 100
102 In the Matter of Google 

Inc., File No. 102-

3036, Docket No. C4336 (Mar. 30, 2011) 

Defendant alleged to have 

used deceptive tactics and 

violated its privacy 

promises to consumers 

when it launched its social 

network, Google Buzz. 

Defendant also alleged to 

have violated the 

substantive privacy 

requirement of the U.S.-

EU Safe Harbor 

Framework. 

As part of a settlement, 

defendant is required to 

conduct independent 

privacy audits for the next 

20 years. 

Data transfers under the 

U.S-EU Safe Harbor 

Privacy framework. 

FTC Charges Deceptive 

Privacy Practices in Googles 

Rollout of Its Buzz Social 

Network 

2010

103 U.S. v. Allied 

Interstate, Inc., No. 

0:10-cv-04295-PJSAJB (D. MN. Oct. 21, 

2010) 

Defendant alleged to have 

continued debt collection 

efforts after consumers 

told the company they did 

not owe the debt, without 

verifying the accuracy of 

the disputed information. 

Defendants also alleged to 

have made improper 

harassing phone calls to 

consumers and to have 

revealed debts to third 

parties. 

Defendant operated out of 

offices in the United 

States, Canada, India, and 

the Philippines. 

Debt Collector Will Pay 

$1.75 Million to Settle FTC 

Charges 

FEDERAL TRADE COMMISSION • FTC.GOV 101
Defendants ordered to pay 

$1.75 million as part of 

settlement. 

104 FTC v. Iovate Health 

Scis. USA, No. 10-CY587 (W.D. N.Y. July 

14, 2010) 

Defendants alleged to 

have falsely advertised 

that its supplements could 

help consumers lose 

weight and treat or prevent 

colds and other illnesses. 

Defendants ordered to pay 

$5.5 million as part of 

settlement. 

Defendants include a 

Canadian parent company 

and another Canadian 

subsidiary of that 

company. 

Dietary Supplement Maker t

Pay $5.5 Million to Settle 

FTC False Advertising 

Charges 

105 FTC v. Asia Pac. 

Telecom, Inc., No. 10 

C 3168 (N.D. Ill. May 

24, 2010) 

Defendant alleged made 

more than 370 million 

calls to consumers 

nationwide in one year 

alone in violation of the 

Do Not Call Registry 

Rule. 

Defendant operated out of 

various locations, 

including in the Northern 

Mariana Islands, Hong 

Kong, and the 

Netherlands. 

At FTC's Request, Court 

Halts Massive Robocall 

Operation (June 10, 2010) 

106 FTC v. Advanced 

Mngt. Servs. NW LLC, 

No. CV-10-0148-LRS 

(E.D. Wa. May 10, 

2010) 

Defendants alleged to 

have made calls to 

consumers nationwide, 

claiming that they could 

negotiate with credit card 

issuers to substantially 

lower the interest rates on 

the consumers’ credit 

cards. Defendants also 

alleged to have delivered 

prerecorded “robocalls” 

FTC was assisted in the 

investigation by Toronto 

Strategic Partnership, 

which includes as member 

agencies the Competition 

Bureau Canada, the 

Toronto Police Service 

Fraud Squad – Mass 

Marketing Section, the 

Ontario Provincial Police 

Anti-Rackets Section, the 

Ontario Ministry of 

Consumer Services, the 

At FTC's Request, Court 

Stops Deceptive 

Telemarketing Calls Pitching 

Credit Card Interest Rate 

Reduction (May 20, 2010)   

FEDERAL TRADE COMMISSION • FTC.GOV 102
that consisted of urgentsounding messages. 

Royal Canadian Mounted 

Police, and the U.K.’s 

Office of Fair Trading. 

2009

107 FTC v. MoneyGram 

Int’l, No. 1:09-cv06576 (N.D. Ill. Oct. 

19, 2009) 

Defendants alleged to 

have allowed their money 

transfer system to be used 

by fraudulent 

telemarketers to bilk 

consumers out of tens of 

millions of dollars. 

Defendants settled the 

charges. 

In 2018, the company 

agreed to pay $125 million 

to settle allegations that it 

failed to take steps 

required under the 2009 

order to crack down on 

fraudulent money transfers 

that cost U.S. consumers 

millions of dollars. 

Canadian agents allegedly 

used MoneyGram outlets 

in Canada to 

defraud U.S. consumers. 

MoneyGram to Pay $18 

Million to Settle FTC 

Charges That it Allowed its 

Money Transfer System to 

Be Used for Fraud 

108 FTC v. Javian Karnani, 

No. 09-CV-5276 (C.D. 

Cal. July 20, 2009) 

(a/k/a Best Priced 

Brands, LLC) 

The FTC alleged that 

defendants deceptively 

advertised and sold 

consumer electronic 

products, such as cameras, 

video game systems, and 

computer software, via 

The case exclusively 

targeted 

consumers in the U.K. 

U.K. authorities also 

assisted the FTC with this 

investigation. Many 

consumers in the U.K. 

registered complaints with 

Court Halts U.S. Internet 

Seller Deceptively Posing as 

U.K. Home Electronics Site 

FEDERAL TRADE COMMISSION • FTC.GOV 103
the internet to consumers 

in the U.K. 

the FTC through 

econsumer.gov. 

109 FTC v. Diamond 

Phone Card, Inc., No. 

09-CV-3257 (E.D.N.Y. 

July 29, 2009) 

Defendants alleged to 

have misrepresented the 

number of calling minutes 

consumers could obtain 

using prepaid calling cards 

created and/or distributed 

by defendants, and failed 

to disclose, or disclose 

adequately, fees that had 

the effect of reducing the 

number of calling minutes 

available to consumers 

using prepaid calling cards 

created and/or distributed 

by defendants. 

The consumer protection

agencies in El Salvador, 

Colombia, Egypt, 

Mexico, 

Panama, and Peru assisted 

the 

FTC with this 

investigation. 

110 FTC v. Paul Navestad, 

No. 09 CV

6329T (W.D.N.Y. June 

25, 2009) (a/k/a Cash 

Grant Institute) 

Defendants alleged to 

have waged an automated 

robocall campaign 

promoting bogus claims 

that consumers were 

qualified for grant money 

from the government, 

private foundations, and 

wealthy individuals. 

In 2012, federal judge 

ordered the defendants to 

pay a total of $30 million 

in civil penalties and give 

up more than $1.1 million 

in ill-gotten gains. The 

court order includes a $20 

The defendants conducted 

business through 

companies that were 

purportedly based abroad.

FTC Cracks Down on 

Scammers Trying to Take 

Advantage of the Economic 

Downturn 

FEDERAL TRADE COMMISSION • FTC.GOV 104
million judgment against 

Paul Navestad. 

In 2014, a federal judge 

ordered the arrest and 

incarceration of Paul 

Navestad for the court 

order. 

111 FTC v. MCS 

PROGRAMS, LLC, No. 

C09-5380RBL (W.D. 

Wa. June 25, 2009) 

Defendants alleged to 

have used cold calls, prerecorded “robocalls,” and 

the internet to push a 

phony “Rapid Debt 

Reduction” program to 

consumers in the United 

States and Canada. 

The scheme impacted 

consumers in the U.S. and 

Canada. The FTC also 

received assistance from 

the Canadian Competition 

Bureau. 

FTC Cracks Down on 

Scammers Trying to Take 

Advantage of the Economic 

Downturn (July 1, 2009) 

112 FTC v. In Deep Servs., 

Inc., No. 09-CV-01193 

(C.D. Cal. June 23, 

2009) 

Defendants alleged to 

have deceived consumers 

by promising them free 

government grant money 

to use for personal 

expenses or to pay off 

debt. The defendants 

allegedly failed to disclose 

adequately that consumers 

would be enrolled in a 

membership program that 

cost as much as $94.89 a 

month. 

Defendant used an 

offshore payment 

processor. 

FTC Cracks Down on 

Scammers Trying to Take 

Advantage of the Economic 

Downturn (July 1, 2009) 

113 FTC v. Wagner Ramos 

Borges, No. 09-CVDefendant alleged to have operated a bogus 

employment scam. 

The defendant was 

allegedly located abroad. 

FTC Cracks Down on 

Scammers Trying to Take 

FEDERAL TRADE COMMISSION • FTC.GOV 105
1634 (D. Md. June 22, 

2009) 

Advantage of the Economic 

Downturn (July 1, 2009) 

114 FTC v. 6654916 

Canada Inc., a 

Canadian Corporation, 

d/b/a National Yellow 

Pages Online Inc., No. 

09C 3159 (N.D. Ill. 

May 27, 2009) 

The FTC alleged that 

defendants deceptively 

marketed directory listings 

to businesses and other 

organizations in the 

United States. 

The Canadian 

Competition Bureau and 

Project COLT, a multiagency, U.S.-Canada 

partnership formed in the 

1990s to combat 

telemarketing fraud, 

assisted with this 

investigation. The 

defendants were based in 

Canada. 

FTC Sues to Halt Three 

Cross-Border Business 

Directory Scams (June 2, 

2009) 

115 FTC v. Integration 

Media Inc., a 

corporation, d/b/a 

GoAm Media, No. 09C 

3160 (N.D. Ill. May 27, 

2009) 

The FTC alleged that 

defendants deceptively 

marketed directory listings 

to businesses and other 

organizations in the 

United States. 

The Canadian 

Competition Bureau and 

Project COLT, a multiagency, U.S.-Canada 

partnership formed in the 

1990s to combat 

telemarketing fraud, 

assisted with this 

investigation. The 

defendants were based in 

Canada. 

FTC Sues to Halt Three 

Cross-Border Business 

Directory Scams (June 2, 

2009) 

116 FTC v. 6253547 

Canada, Inc., No. 

1:09CV01211 (N.D. 

Ill. May 27, 2009) 

(consolidated with FTC 

v. Integration Media, 

Inc. after initial filing) 

The FTC alleged that 

defendants deceptively 

marketed directory listings 

to businesses and other 

organizations in the 

United States. 

The Canadian 

Competition Bureau and 

Project COLT, a multiagency, U.S.-Canada 

partnership formed in the 

1990s to combat 

telemarketing fraud, 

assisted with this 

investigation. The 

FEDERAL TRADE COMMISSION • FTC.GOV 106
defendants were based in 

Canada. 

117 FTC v. 6555381 

Canada, Inc., a 

corporation, d/b/a 

Reed Publishing, No. 

09C 3158, (N.D. Ill. 

May 27, 2009) 

The FTC alleged that 

defendants deceptively 

marketed directory listings 

to businesses and other 

organizations in the 

United States. 

The Canadian 

Competition Bureau and 

Project COLT, a multiagency, U.S.-Canada 

partnership formed in the 

1990s to combat 

telemarketing fraud, 

assisted with this 

investigation. The 

defendants were based in 

Canada. 

FTC Sues to Halt Three 

Cross-Border Business 

Directory Scams 

118 FTC v. Sean Cantkier, 

No. 09-CV-00894 

(D.D.C. May 14, 

2009) 

The defendants allegedly 

diverted consumers who 

searched online for the 

free government mortgage 

loan assistance program to 

commercial websites that 

offer loan modification 

services for a fee. 

One of the defendants was 

located in Malaysia. 

FTC Obtains Court Order 

Halting Deceptive Mortgage 

Relief Internet Ads; 

Marketers Falsely Claimed t

Operate 

MakingHomeAffordable.gov

119 FTC v. Romeo, No. 

2:09-cv-01262-WJMCCC (D.N.J. Mar. 20, 

2009) 

The defendants allegedly 

made false and deceptive 

claims when advertising 

purported hoodia products 

to trade customers. 

The defendants sold 

products in the United 

States and other 

countries. 

FTC Charges Marketers of 

Hoodia Weight Loss 

Supplements with Deceptive 

Advertising 

2008

FEDERAL TRADE COMMISSION • FTC.GOV 107
120 FTC v. Innovative 

Mktg., Inc., Civil 

Action No. RDB 

08CV3233 (D. Md. 

Dec. 2, 2008) 

Defendants allegedly 

misrepresented that they 

conducted scans of 

consumers’ computers and 

falsely indicated that the 

scans detected a variety of 

security or privacy issues.

The case included British 

and Canadian defendants. 

One of the companies was 

incorporated in Belize and 

maintained offices in the 

Ukraine. 

Court Halts Bogus Computer 

Scans 

121 FTC v. Cash Today,

Ltd., No. 3:08-

cv00590-BES-VPC (D. 

Nev. Nov. 6, 2008) 

Defendants alleged to 

have violated the FTC 

Act, Truth in Lending Act, 

and Regulation Z by not 

disclosing key loan terms 

to U.S. consumers and 

using abusive and 

deceptive debt collection 

tactics. 

Some of the defendants 

were based in the United 

Kingdom. The UK’s 

Office of Fair Trading 

assisted the FTC with this 

investigation. 

FTC Charges Internet Payda

Lenders with Failing to 

Disclose Key Loan Terms 

and Using Abusive and 

Deceptive Collection Tactics

122 FTC v. CyberSpy 

Software, LLC, No. 08-

cv08172 (M.D. Fla. 

Nov. 5, 2008) 

Defendants alleged to 

have sold keylogging 

spyware to clients who 

may have used it to 

secretly monitor 

unsuspecting consumers’ 

computers. 

Some clients reported 

purchasing the software 

from people online who 

they now suspect are 

foreign scam artists. 

Court Orders Halt to Sale of 

Spyware 

123 FTC v. 9163-7710 

Québec, Inc., No. 3:08-

Defendants allegedly 

violated the FTC Act by 

misrepresenting that they 

This case was brought 

with the assistance of the 

Royal Canadian Mounted 

FTC Stops Fake 'Yellow 

Pages' Marketers Who Bilke

FEDERAL TRADE COMMISSION • FTC.GOV 108
CV02131-GAG 

(D.P.R. Oct. 28, 2008)

had preexisting 

relationships with 

consumers, that consumers 

had agreed to purchase 

defendants’ services, and 

that consumers owed 

money for defendants’ 

services 

Police and Project COLT, 

a multi-agency, U.S.- 

Canada initiative formed 

in the 1990s to combat 

telemarketing fraud. 

Spanish-Speaking Businesse

in Cross-Border Scam 

124 FTC v. RCA Credit 

Servs., LLC, No. 8:08-

CV2062-T-27MAP 

(M.D. Fla. Oct. 16, 

2008) 

Defendants allegedly 

operated a deceptive credit 

repair scheme and failed 

to comply with 

requirements of the Credit 

Repair Organizations Act 

Some of the defendants 

were located in the 

Philippines 

‘Operation Clean Sweep’: 

FTC and State Agencies 

Target 36 ‘Credit Repair’ 

Operations 

125 FTC v. Atkinson, No. 

08-CV-5666 (N.D. Ill. 

Oct. 9, 2008) 

Defendants violated the 

FTC Act and CAN-SPAM 

Act by deceptively 

marketing a variety of 

products through spam 

messages, including a 

male-enhancement pill, 

prescription drugs, and a 

weight loss pill. 

Defendants operated in 

Australia, New Zealand, 

Cyprus, and the United 

States. The New Zealand 

Department of Internal 

Affairs and the Australian 

Communications and 

Media Authority provided 

assistance with this 

investigation. 

FTC Shuts Down, Freezes 

Assets of Vast International 

Spam E-Mail Network 

126 FTC v. Nu-Gen 

Nutrition, Inc., No. 

1:08-cv- 05309 (N.D. 

Ill Sept. 18, 2008) 

Defendants alleged to 

have deceptively 

advertised bogus cancer 

remedies. 

Defendants sold cancer 

remedies to victims in 

foreign countries. 

FTC Sweep Stops Peddlers 

of Bogus Cancer Cures 

FEDERAL TRADE COMMISSION • FTC.GOV 109
127 FTC v. Advanced 

Patch Techs., Inc., No. 

1:04-CV-0670 (N.D. 

Ga. Mar. 10, 2004) 

(modified settlement 

Sept. 16, 2008) 

Defendants allegedly 

violated a 2004 FTC 

consent order by 

continuing to make false 

claims about their weightloss product. 

Defendants made 

deceptive claims in 

brochures accompanying 

product shipments 

intended for sale to 

overseas consumers. 

Marketers of Weight-Loss 

Patch to Pay More Than 

$110,000 for Violating 

Previous FTC Settlements 

128 FTC v. 9107-4021 

Québec, Inc., a 

corporation, also d/b/a 

Med Provisions, No. 

1:08-cv-01051- DCN 

(N.D. Ohio Aug. 12, 

2008) 

Defendants allegedly 

violated the FTC Act and 

the Telemarketing Sales 

Rule by making 

misrepresentations to U.S. 

consumers about an online 

pharmacy and their 

Medicare benefits. 

Defendants were based in 

Montreal, Canada. 

Canada’s Competition 

Bureau provided 

substantial investigative 

assistance in this case. 

FTC Announces Operation 

Tele-PHONEY, Agency's 

Largest Telemarketing 

Sweep 

129 FTC v. 6554962 

Canada Inc., d/b/a 

Union Consumer 

Benefits, No. 1:08-cv02309 (N.D. Ill. Apr. 

23, 2008) 

Defendants violated the 

FTC Act and the 

Telemarketing Sales Rule 

by telemarketing 

worthless medical 

discount packages to 

elderly consumers 

throughout the United 

States. Defendants also 

violated the law by calling 

many consumers on the 

Do Not Call Registry. 

Defendants were based in 

Canada. Canada’s 

Competition Bureau 

assisted with this 

investigation. 

FTC Announces Operation 

Tele-PHONEY, Agency's 

Largest Telemarketing 

Sweep 

130 FTC v. NHS Sys., Inc., 

No. 08-cv-2215 (E.D. 

Pa. May 13, 2008) 

Defendants allegedly 

engaged in deceptive 

telemarketing and 

unauthorized billing 

practices. They purported 

to contact consumers on 

behalf of government 

Key defendants were 

based in Canada and St. 

Lucia. Canadian 

authorities assisted with 

serving process on some 

FTC Announces Operation 

Tele-PHONEY, Agency's 

Largest Telemarketing 

Sweep 

FEDERAL TRADE COMMISSION • FTC.GOV 110
agencies and charged 

consumers to enroll in 

programs without their 

consent. 

of the defendants located 

in Canada. 

131 FTC v. Datacom 

Mktg.,Inc., No. 06 C 

2574 (N.D. Ill. May 6, 

2008) 

Defendants ran a crossborder fraud operation 

scamming American 

businesses into paying for 

business directories and 

listings they did not order.

Canada’s Competition 

Bureau, the Service de 

Police de la Ville de 

Montreal, and the Toronto 

Strategic Partnership 

assisted with this 

investigation. 

Court Halts Canadian 

Operation Charging for 

Unordered and Unwanted 

Business Directory Listings 

132 FTC v. Data Bus. 

Solutions Inc., No. 08-

CV- 2783 (ND. Ill. 

May 14, 2008) 

Defendants alleged to 

have run a cross- border 

fraud operation scamming 

American businesses and 

non-profit organizations 

by sending them fake 

invoices disguised to look 

like annual bills from their 

existing domain name 

registrars for their 

websites. 

Competition Bureau 

Canada, the Toronto 

Police Service – Fraud 

Squad, the Ontario 

Ministry of Government 

Services, the Ontario 

Provincial Police – AntiRackets, the Royal 

Canadian Mounted Police, 

and the United Kingdom’s 

Office of Fair Trading 

assisted with this 

investigation. The FTC’s 

attorney on detail at DOJ’s 

Office of Foreign 

Litigation worked with 

foreign counsel to file an 

application seeking to 

compel evidence in a 

Canadian court that could 

be used in the domestic 

proceeding 

FTC Halts Cross Border Con 

Artists 

FEDERAL TRADE COMMISSION • FTC.GOV 111
133 FTC v. Alternatel, Inc., 

No. 1:08-cv-21433-AJ 

(S.D. Fla. May 19, 

2008) 

Defendants allegedly 

violated the FTC Act by 

misrepresenting the 

number of calling card 

minutes consumers could 

use to contact people in 

foreign countries, failing 

to disclose that 

consumers’ cards would 

be charged whether or not 

the calls went through, and 

charging hidden fees. 

The consumer protection 

agencies in Colombia, 

Egypt, El Salvador, 

Mexico, Panama, and Peru 

aided in this 

investigation. 

FTC Halts Bogus Prepaid 

Phone Card Claims, Cards 

Failed to Deliver the Numbe

of Minutes Promised in Ads 

134 FTC v. Clifton 

Telecard Alliance One 

LLC, No. 2:08-cv1480-pgs-es (D.N.J. 

Apr. 2, 2008) 

Defendants allegedly 

violated the FTC Act by 

misrepresenting the 

number of calling card 

minutes consumers could 

use to contact people in 

foreign countries, failing 

to disclose that 

consumers’ cards would 

be charged whether or not 

the calls went through, and 

charging hidden fees. 

The consumer protection 

agencies in Colombia, 

Egypt, El Salvador, 

Mexico, Panama, and Peru 

provided assistance with 

this investigation. 

FTC Asks Court to Halt 

Prepaid Calling Card Scam; 

Alleges Consumers Receive 

Fewer Calling Minutes Than 

Advertised and Pay Hidden 

Fees 

2007

135 FTC v. Your Money 

Access, LLC, No. 07-

547 (E.D. Pa. Dec. 6, 

2007)

Defendants, including a 

payment processing 

company, allegedly 

violated federal and state 

laws by debiting, or 

attempting to debit, money 

from consumers’ bank 

accounts on behalf of 

Defendants’ clients 

included foreign entities 

such as Canadian 

telemarketers. 

FEDERAL TRADE COMMISSION • FTC.GOV 112
numerous fraudulent 

telemarketers and Internetbased merchants. 

136 FTC v. B.C. Ltd. 

0763496, d/b/a Cash 

Corner Services, Inc., 

No. C07-1755 (W.D. 

Wa. Nov. 19, 2007) 

Defendants violated the 

FTC Act and the 

Telemarketing Sales Rule 

by running a bogus lottery 

and prize promotion scam 

that provided consumers 

with counterfeit cashier’s 

checks and false promises 

of large prizes. 

Defendants were based in 

Canada. 

Court Halts Bogus Check 

Scam Targeting Lottery 

Winners; Money Transfers 

Used to Defraud Consumers 

137 FTC v. Spear Sys., Inc., 

No. 07C-5597 (N.D. 

Ill. Oct. 3, 2007) 

(complaint amended 

May 15, 2008) 

Defendants violated the 

FTC Act and the CANSPAM Act by sending 

deceptive e-mail messages 

about hoodia weight-loss 

products and human 

growth hormone antiaging 

products and making 

claims about those 

products that were false 

and unsubstantiated. 

Defendants were based in 

Australia and Canada. 

FTC Stops International 

Spamming Enterprise that 

Sold Bogus Hoodia and 

Human Growth Hormone 

Pills 

138 FTC v. Practical 

Mktg., Inc., No. 3:07-

cv00685-JPG-DGW 

(S.D. Ill. Sept. 28, 

2007) 

Defendants allegedly 

violated the FTC Act and 

the Telemarketing Sales 

Rule by assisting 

telemarketers who were 

purchasing lists in order to 

solicit U.S. consumers to 

pay advance fees to get 

“guaranteed” credit cards 

with substantial credit 

Defendants sold lists to 

Canadian telemarketers. 

Federal Enforcers Target Lis

Brokers 

FEDERAL TRADE COMMISSION • FTC.GOV 113
limits. The lists included 

consumers’ credit card and 

bank account information, 

exposing thousands of 

consumers to possible 

identity theft, and 

violating federal law. 

139 FTC v. Sili 

Neutraceuticals, LLC, 

No. 07C 4541 (N.D. 

Ill. Aug. 13, 2007) 

Defendants violated the 

FTC Act and the CAN 

SPAM Act by sending 

deceptive e-mail messages 

about hoodia weight-loss 

products and human 

growth hormone antiaging products and 

making claims about those 

products that were false 

and unsubstantiated. 

Defendants’ companies 

were based in the 

Caribbean. 

FTC Stops Spammers Sellin

Bogus Hoodia Weight-Loss 

Products and Human Growth 

Hormone Anti-Aging 

Products 

140 FTC v. 9131-4740 

Québec, Inc., a 

corporation, also d/b/a 

Fusion Telekom, No. 

07-cv-02242 (N.D. 

Ohio Jul. 25, 2007) 

Defendants allegedly 

violated the Telemarketing 

Sales Rule and the FTC 

Act by deceptively 

marketing telephone 

calling cards. 

Defendants were based in 

Canada. 

Cross-Border Telemarketers 

Face FTC Charges for 

Deceptive Phone Card 

Pitches 

141 FTC v. Crystal Ewing, 

FTC No. 062- 3025 (D. 

Nev. Apr. 11, 2007). 

Defendants allegedly ran a 

deceptive prize promotion 

scheme. 

Defendants targeted 

consumers in the United 

States, Canada, and the 

United Kingdom. 

Sweepstakes Promoters Will 

Pay $1.4 Million To Settle 

FTC Charges 

FEDERAL TRADE COMMISSION • FTC.GOV 114
142 FTC v. Mystery Shop 

Link, LLC, No. CV07- 

01791 SJO (Shx) (C.D. 

Cal. Mar. 16, 2007). 

Defendants allegedly 

deceptively marketed a 

mystery shopper job 

program to consumers. 

Defendants targeted 

consumers in the United 

States and Canada. One of 

the defendants was located 

in Australia. 

Enigma for Consumers: 

What Mystery Shopping 

Jobs? 

143 FTC v. Select 

Personnel Mgmt., Inc., 

No. 07C 0529 (N.D. 

Ill. Jan. 29, 2007) 

Defendants engaged in 

fraudulent telemarketing 

to consumers throughout 

the United States, falsely 

claiming they could 

reduce consumers’ credit 

card interest rates. 

Defendants were based in 

Canada. 

FTC Stops Credit Card Rate 

Reduction Scam 

144 FTC v. Lane LabsUSA, Inc., No. 

00CV3174 (D.N.J. 

June 29, 2000) 

(contempt action filed 

Jan. 12, 2007) 

Defendants allegedly 

violated a 2000 FTC order 

prohibiting deceptive 

advertising claims and 

requiring reliable and 

scientific evidence to 

substantiate advertising 

claims. 

The FTC deposed an 

expert witness in Canada.

FTC Files Civil Contempt 

Action Against Lane Labs 

Defendants 

145 FTC v. International 

Prod. Design, Inc., No. 

1:97-CV-01114-AVB 

Defendants allegedly 

violated a 1998 order 

prohibiting them from 

deceptively marketing 

One of the original 

corporate defendants was 

FTC Charges Invention 

Promotion Swindlers with 

Contempt 

FEDERAL TRADE COMMISSION • FTC.GOV 115
(E.D. Va. contempt 

action Jan. 8, 2007) 

invention promotion 

services. 

based in the United 

Kingdom. 

FEDERAL TRADE COMMISSION • FTC.GOV 116