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"
$2.5B
A federal court approved a revised order in the FTC's Amazon Prime case under which Amazon will accelerate and expand redress payments under the September 2025 $2.5 billion settlement, which resolved allegations that Amazon enrolled millions of consumers in Prime subscriptions without their consent and knowingly made cancellation difficult. More consumers now qualify for refunds, the maximum payment cap rises from $51 to $200, and all future payments will be distributed automatically starting October 1, 2026, with potential supplemental $149 payments by April 2027. Amazon has already issued more than $845 million in redress payments as of September 2026.
$225.0M
The FTC and the state of Washington filed a joint complaint and proposed stipulated order requiring Amway Corp. and two affiliates—World Wide Group, L.L.C. (WWG) and Leadership Team Development Inc. (LTD)—to pay a $225 million judgment, the largest monetary recovery ever obtained from an MLM in an FTC action, over allegations that they used deceptive earnings claims and unfair tactics to recruit Independent Business Owners. The complaint alleges the companies falsely promised substantial income and recruitment success, pressured IBOs to buy products they could not resell, and instructed IBOs to falsely report sales. Nearly all of the judgment will be used as redress for IBOs who lost money, and the proposed order imposes structural reforms including a 70% resale requirement, independent audits of sales records, and a ban on approved providers charging new IBOs for first-year training.
$100.0M
FleetCor Technologies Inc. (now Corpay Inc.) and its CEO Ronald Clarke agreed to pay $100 million to settle an FTC administrative action alleging the company charged small business customers hidden and unauthorized fees for fuel cards and misrepresented gas savings, fraud-control features, and fees. A federal district court granted the FTC summary judgment on all counts in 2023, and a federal appeals court upheld that judgment and the permanent injunction in 2026. The settlement funds will be used to provide redress to harmed business customers.
FTC staff published FAQs on price transparency to help the automobile industry comply with the FTC Act, reiterating that an advertised vehicle price must be the actual price any consumer can pay, excluding only government-required charges. The guidance follows warning letters the FTC sent to 97 auto dealership groups earlier in 2026 and signals continued litigation against dealers that advertise one price but charge more through undisclosed fees. No specific entity was charged and no penalty was imposed.
The FTC rescinded its 2021 Policy Statement on Breaches by Health Apps and Other Connected Devices, which had purported to apply the Health Breach Notification Rule to health apps and connected devices that collect consumer health information. The rescission follows the Commission's 2024 update to the Health Breach Notification Rule, which already covers health apps and connected devices like fitness trackers, and implements an executive order directing agencies to eliminate obsolete guidance documents. No company was charged or penalized; this is a deregulatory action.
$12.0M
The FTC alleged that payment processor Humboldt Merchant Services knowingly processed payments for more than 1,000 shell merchant entities serving as fronts for fraudulent companies engaged in unauthorized billing scams, despite red flags including chargeback rates nearly 10 times higher than card-brand thresholds. Under the proposed stipulated order filed in the U.S. District Court for the Eastern District of Michigan, Humboldt will pay $12 million for consumer redress and is permanently banned from processing payments for merchants with a heightened risk of potential fraud.