Businesses making negative option or auto-renewal subscription offers, beware: Federal Trade Commission (FTC or Commission) enforcement is alive and well in 2025. Although the U.S. Court of Appeals for the Eighth Circuit struck down the FTC’s much-criticized Biden-era “click to cancel” rule earlier this summer, on September 25, 2025 the FTC announced that Amazon.com, Inc. and two of its senior executives agreed to pay $1 billion in FTC fines and another $1.5 billion in consumer refunds to settle allegations that Amazon “knowingly duped millions of consumers into unknowingly enrolling in its Amazon Prime service” and intentionally made Prime membership difficult to cancel. The FTC asserts that the Amazon settlement is just the third time in which the FTC has obtained a civil penalty under the Restore Online Shoppers’ Confidence Act (ROSCA) and represents the second-largest restitution award ever obtained by the FTC.
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Additionally, see Amazon’s statement about the FTC settlement here.