Court Rules
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SettlementMedium Risk

FTC Fines Experian $650K for CAN-SPAM Opt-Out Violations

Experian Consumer ServicesAugust 14, 2023Federal Trade Commission

Penalty Amount

$650,000

Summary

The FTC settled charges against Experian Consumer Services for violating the CAN-SPAM Act by sending marketing emails to consumers who signed up for credit management accounts without providing an opt-out mechanism. The emails promoted products like Experian Boost and Dark Web scans but lacked unsubscribe links. Experian must pay $650,000 and is prohibited from future violations.

Remedy

Experian must pay a $650,000 penalty and is enjoined from sending marketing emails without an opt-out mechanism through a consent decree.

Monetary PenaltyInjunctionConsent Decree

Contract Impact

In-house legal teams should review all customer-facing agreements, particularly those for credit management, credit monitoring, or identity protection services (e.g., Experian Boost enrollment). Focus on clauses governing marketing communications, consent to receive promotional emails, and the specific mechanism provided for opting out. Agreements must clearly distinguish between transactional/account-related messages and marketing offers, and must include a functional, conspicuous unsubscribe method in every marketing email as mandated by the CAN-SPAM Act. Teams should audit how consent is obtained during account sign-up and ensure marketing email practices align with the explicit terms of the customer agreement. Updates may be needed to add or clarify opt-out instructions, revise consent language, and implement processes to honor opt-out requests promptly.

Contract Search Terms

opt-out mechanismunsubscribe linkmarketing email consentaccount agreement marketing clauseCAN-SPAM compliancetransactional vs. marketing email definitionclear and conspicuous noticeemail consent record-keepingcredit management account termsdata processing addendum

Laws Cited

CAN-SPAM Act

Violation Types

Entity Details

Entity

Experian Consumer Services

Also known as: Experian

Industry

Financial Services

Official Sources

Source Evidence

Entity Name
"Experian Consumer Services"
Fine Amount
"$650,000"
Laws Cited
"CAN-SPAM Act"
Violation Types
"failed to provide clear and conspicuous notice of consumers’ ability to opt out"
Violation Types
"did not contain an unsubscribe link"

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