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FTC Seeks Contempt Against Cliq for $52.9M Consent Order Violations

Cliq, Inc., Andrew Phillips, John BlaugrundJanuary 13, 2026Federal Trade Commission

Penalty Amount

$52,900,000

Summary

The FTC filed a motion in federal court seeking to hold payment processor Cliq, Inc. and its operators in contempt for systematically violating a 2015 consent order. The defendants are accused of processing payments for high-risk and prohibited merchants, failing to screen for deceptive practices, and facilitating fraud avoidance tactics. The FTC is requesting at least $52.9 million in consumer relief, a permanent ban on the individuals from payment processing, and appointment of a receiver.

Remedy

The FTC seeks compensatory relief of at least $52.9 million for consumers, a permanent ban on Andrew Phillips and John Blaugrund from the payment processing business, modification of the 2015 order, and appointment of a receiver to oversee Cliq's compliance.

Monetary PenaltyBanAudit RequirementInjunction

Contract Impact

In-house legal teams should review all vendor agreements with payment processors and customer/merchant agreements for clauses related to compliance with consent orders, fraud prevention, and merchant screening. Specifically, examine representations and warranties regarding lawful processing, obligations to implement and maintain fraud detection and transaction monitoring systems, requirements to maintain and adhere to a prohibited merchant list, and audit/cooperation clauses. Given the allegations of processing for high-risk/prohibited merchants and ignoring red flags, contracts may need amendments to include stricter underwriting standards, mandatory real-time screening against updated prohibited lists, enhanced reporting obligations, and clear termination rights for non-compliance with regulatory orders.

Contract Search Terms

merchant underwriting standardshigh-risk merchant processingfraud detection protocolsconsent order compliancepayment processor agreementrisk assessment clauseprohibited merchant listtransaction monitoringred flag detectionaudit rights

Laws Cited

FTC Act Section 52015 Consent Order
2015 Consent Order

Violation Types

Entity Details

Entity

Cliq, Inc., Andrew Phillips, John Blaugrund

Also known as: Cliq

Industry

Financial Services

Official Sources

Source Evidence

Entity Name
"Cliq, Inc., formerly Cardflex, Inc., along with its operators, CEO Andrew Phillips and Chief Technology and Security Officer John Blaugrund"
Fine Amount
"seeking at least $52.9 million in relief for consumers"
Laws Cited
"violating their 2015 order with the agency"
Violation Types
"Processing hundreds of millions of dollars in payments for at least three clients on Mastercard’s Member Alert To Control High (MATCH) list"
Violation Types
"Failing to monitor high-risk clients’ sales and transactional activity to determine whether their businesses are engaged in practices that are deceptive"

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