Attorney General William Tong of Connecticut led a bipartisan coalition of 30 state attorneys general in submitting comments to the Federal Trade Commission. The comments aim to improve collaboration between the FTC and state AGs to prevent and prosecute unfair and deceptive practices, addressing issues raised by the AMG Capital decision that may limit restitution. The coalition emphasizes the importance of joint efforts for national consumer protection.
In-house legal teams should review vendor, customer, and data processing agreements for clauses related to compliance with unfair or deceptive acts or practices (UDAP), restitution and remedy provisions, and obligations to cooperate with regulatory investigations. Specific attention should be paid to terms governing joint enforcement, cross-border matters, and the availability of state law remedies, as the coalition's comments highlight potential limitations on restitution following the AMG Capital decision. Agreements may need amendments to clarify cooperation protocols with both the FTC and state attorneys general, ensure alignment with the FTC Collaboration Act of 2021, and address the expanded use of state consumer protection laws in joint actions.
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https://portal.ct.gov/ag/press-releases/2023-press-releases/attorney-general-tong-leads-bipartisan-coalition-in-providing-comments-to-ftc
comment ltr to ftc sig merge 30 final.pdf?rev=c937e4fbeedf4b
https://portal.ct.gov/-/media/ag/press_releases/2023/comment-ltr-to-ftc-sig-merge-30-final.pdf?rev=c937e4fbeedf4baf89350c5d3e2c80be&hash=FFCE7DD7097F7E89D9FA803A840D8EA9
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
The Federal Trade Commission (FTC) announced it submitted a draft Advance Notice of Proposed Rulemaking (ANPRM) regarding online food delivery service fees to the Office of Management and Budget (OMB) for review on April 10, 2026. The ANPRM is classified as a 'significant regulatory action' under Executive Orders 12866 and 14215, requiring review by OIRA before public issuance. This press release does not describe an enforcement action against a private entity, nor any privacy-related violations or penalties.
On March 20, 2026, FTC Chairman Andrew N. Ferguson directed FTC staff to form a Healthcare Task Force to coordinate healthcare enforcement and advocacy efforts. The task force will focus on targeted enforcement initiatives, agencywide investigation strategies, amicus opportunities, and identifying emerging enforcement priorities. It will also seek partnerships with other federal agencies including HHS and DOJ to advance healthcare competition and consumer protection.
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.