Penalty Amount
$140,000,000
Following an FTC investigation, a federal court granted summary judgment against timeshare exit scheme operator Christopher Carroll, ordering him to pay $140 million total ($95 million in consumer redress, $45 million civil penalty) for defrauding consumers out of over $90 million. The scheme used deceptive direct mail and in-person pitches, falsely claimed affiliation with timeshare companies, failed to provide refunds, and violated the FTC’s Cooling-Off Rule by forcing consumers to sign non-cancellable contracts. Carroll is also permanently banned from marketing timeshare exit services or engaging in deceptive door-to-door sales.
The court ordered Christopher Carroll to pay $140 million total, consisting of $95 million in redress to consumers and a $45 million civil penalty. Carroll is permanently banned from advertising, marketing, promoting, or offering any timeshare exit services, engaging in deceptive door-to-door sales, or other deceptive conduct outlined in the complaint. The order also imposes a permanent injunction barring the specified deceptive practices.
In-house legal teams, particularly those in the real estate or timeshare industries, should review customer-facing and consumer contracts to ensure full compliance with the FTC Cooling-Off Rule, including explicit three-business-day cancellation rights for door-to-door sales. Marketing vendor agreements and sales presentation contracts must be audited to prohibit deceptive claims such as false affiliation with third-party timeshare companies, undisclosed exorbitant fees, and unenforceable non-cancellation clauses. Refund policy clauses should be clear, enforceable, and honored in practice, while all consumer contracts should include representations and warranties against deceptive practices and indemnification provisions for FTC rule violations. Companies using direct mail or in-person sales pitches should also review advertising vendor agreements to align with truth-in-advertising standards.
Entity
Christopher Carroll
Industry
Real EstateOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2026/04/court-orders-operator-timeshare-exit-scheme-pay-140-million-related-ftc-allegations-scheme-took
SquareOne MemorandumandOrder
https://www.ftc.gov/system/files/ftc_gov/pdf/SquareOne-MemorandumandOrder.pdf
SquareOne Permanent Injunction
https://www.ftc.gov/system/files/ftc_gov/pdf/SquareOne-Permanent%20Injunction.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Christopher Carroll"
"$140 million"
"FTC’s Cooling-Off Rule"
"falsely claiming to be associated with timeshare companies; falsely telling consumers that they couldn’t exit a timeshare without paying the defendants’ exorbitant fees; failing to provide promised refunds; and forcing consumers to sign contracts that they were told they couldn’t cancel in violation of the FTC’s Cooling-Off Rule"
"permanently bans Carroll from advertising, marketing, promoting, or offering for sale any timeshare exit service; from engaging in any deceptive door-to-door sales; and from engaging in other deceptive and misleading conduct"
The FTC sent warning letters to 12 companies offering 'nudify' tools that generate nonconsensual intimate images, for failing to comply with the TAKE IT DOWN Act (TIDA) by not providing a mechanism for victims to request removal of such content. The letters urge immediate compliance with TIDA, which requires platforms to remove nonconsensual intimate images within 48 hours of a valid request. Noncompliant companies may face future legal action and civil penalties of up to $53,088 per violation.
The FTC began enforcing the TAKE IT DOWN Act on May 19, 2026, a law requiring covered platforms to establish a process for victims to request removal of nonconsensual intimate images and delete such content within 48 hours of a valid request. The agency launched a consumer complaint portal, issued compliance guidance for businesses and consumers, and sent reminder letters to major platforms including Meta, TikTok, and X about their obligations under the law. No specific penalties or enforcement actions against individual companies were announced in this release.
$6.5M
A federal court held Cliq Inc. and its executives Andrew Phillips and John Blaugrund in civil contempt for multiple violations of a 2015 FTC order requiring the payment processor to prevent enabling consumer fraud. The court found the defendants facilitated fraud by processing transactions for high-risk merchants, avoiding fraud monitoring, failing to conduct required underwriting, and ignoring chargeback thresholds. The court imposed $6.5 million in civil contempt sanctions against the defendants.
$795.8M
The FTC and State of Nevada settled charges with lead defendants of the IM Mastery Academy MLM scheme, including Chris and Isis Terry and their affiliated companies, over false earnings claims used to promote financial training programs and a multi-level marketing venture. The stipulated order imposes a $795.8 million judgment, with defendants surrendering nearly $90 million in assets including luxury real estate, vehicles, jewelry, and a yacht, totaling over $100 million with prior judgments from other involved defendants. The order also bans defendants from selling trading-training services, prohibits false earnings claims, and restricts deceptive practices including negative-option misrepresentations and telemarketing violations.
The FTC and State of Illinois, via the Department of Justice, filed a complaint against B.E.S.T. GDR LLC (d/b/a Premium Home Service) and its owner Yosef Bernath for creating thousands of fake home repair business listings with fabricated five-star reviews to deceive consumers. The defendants allegedly routed consumer calls to unqualified representatives, arranged for unlicensed technicians, and violated the FTC Act, Reviews and Testimonials Rule, Gramm-Leach-Bliley Act, and Illinois consumer protection laws. No monetary penalty has been imposed yet as the case is in initial filing stages.
Federal Trade Commission Chairman Andrew N. Ferguson sent letters to over a dozen major technology companies reminding them of their obligation to comply with the Take It Down Act (TIDA) by May 19, 2026. TIDA requires covered platforms to establish a process for victims, including children, to request removal of nonconsensual intimate images, with takedown of content and all identical copies required within 48 hours of a valid request. The FTC also issued supplemental guidance to help companies prepare for compliance and warned that it will monitor and enforce violations of the law.