Penalty Amount
$186,000,000
The FTC has taken action against Illusory Systems, Inc. (doing business as Nomad) for failing to implement adequate data security measures, which led to a breach where hackers stole $186 million from consumers. The company is required to return the stolen funds and implement an information security program.
Illusory Systems must return the $186 million stolen from consumers and implement a comprehensive information security program.
In-house legal teams should review all agreements where Illusory Systems/Nomad handles consumer data or funds, including vendor agreements (for data processing or payment services), customer agreements (for service terms and security promises), and any payment processing or financial intermediary contracts. Key clauses to scrutinize are data security obligations, breach notification requirements, indemnification provisions, audit rights, and compliance with specific security standards. Given the FTC's order, contracts may need amendments to mandate a documented information security program with regular risk assessments, encryption of sensitive data, multi-factor authentication, and explicit terms for consumer restitution in case of security failures. Teams should also verify if existing agreements sufficiently allocate liability for third-party breaches and require prompt cooperation with regulatory investigations.
Entity
Illusory Systems, Inc.
Also known as: Nomad
Industry
OtherOfficial Press Release
https://www.ftc.gov/legal-library/browse/cases-proceedings/illusory-systemsnomad
NomadComplaintclean
https://www.ftc.gov/system/files/ftc_gov/pdf/NomadComplaintclean.pdf
NomadOrder
https://www.ftc.gov/system/files/ftc_gov/pdf/NomadOrder.pdf
2323016NomadAAPC
https://www.ftc.gov/system/files/ftc_gov/pdf/2323016NomadAAPC.pdf
ftc will require illusory systems return money stolen hacker
https://www.ftc.gov/news-events/news/press-releases/2025/12/ftc-will-require-illusory-systems-return-money-stolen-hackers-implement-information-security-program
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Illusory Systems, Inc., a corporation, also d/b/a Nomad."
"failing to implement adequate data security measures, leading to a major security breach"
"December 16, 2025"
"FTC Will Require Illusory Systems to Return Money Stolen by Hackers and Implement an Information Security Program"
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