In this episode of Payments Pros, host Keith Barnett examines a recent FTC enforcement action targeting an alleged unlawful subscription scheme involving 15 corporations and eight individuals operating through Cyprus- and Ukraine-based entities with access to U.S. payment rails. Keith discusses the FTC’s continued focus on deceptive advertising, undisclosed recurring charges, unauthorized billing, and burdensome cancellation practices, and explains why these issues carry significant implications for companies operating in the payments ecosystem. He walks through the FTC’s five-stage playbook allegations, including the failure to clearly disclose subscription terms, the use of engaging online tasks to drive purchases, and the deliberate obstruction of cancellation mechanisms. Keith also highlights the broad temporary restraining order agreed to by several defendants, covering asset freezes, foreign asset repatriation, customer data protections, and expedited discovery extending to third-party banks and payment processors. The episode closes with a reminder that the Trump-era FTC remains active and aggressive in the payments space, with businesses advised to prioritize clear disclosures, simple cancellation options, and strong BSA compliance practices.
Transcript: FTC’s Subscription Crackdown: What Payment Processors Need to Know (PDF)