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Plain Language Guidance

Business Guidance Concerning Multi-Level Marketing

Date
Multi-level marketing is a diverse industry, employing many different structures and methods of selling. Although there may be significant differences in how multi-level marketers sell their products...

Nudge, LLC

As a result of a lawsuit filed by the Federal Trade Commission and the Utah Division of Consumer Protection (DCP), the principals of a Utah-based real estate investment training company will pay $15 million and be banned from selling money-making opportunities under a court order they have agreed to. In addition, two of the primary real estate celebrities who endorsed the training have agreed to orders that require them to pay $1.7 million.

The Federal Trade Commission is sending more than $10 million in refunds to consumers who paid for a real estate investment training program that allegedly made empty promises about earning big profits “flipping” houses.  

Type of Action
Federal
Last Updated
FTC Matter/File Number
182 3016

Weblio

At the FTC’s request, a federal court has temporarily halted the operation of a sprawling business opportunity scheme that has taken in millions of dollars from consumers with bogus promises of huge returns. The scheme has operated since at least 2018 under a number of names, including “Blueprint to Wealth,” according to the FTC’s complaint. Three individuals -- Samuel James Smith, Robert William Shafer and Charles Joseph Garis, Jr. -- and a company owned by one of them -- Business Revolution Group -- are charged in the complaint with operating the scheme.

Type of Action
Administrative
Last Updated
Case Status
Pending

In re Sanctuary Belize Litigation

In November 2018, the FTC announced that a federal district court in Maryland issued an order temporarily shutting down the largest overseas real estate investment scam the FTC has ever targeted. According to the FTC, the scam was established by Andris Pukke, a recidivist scammer currently living in California, and he perpetuated it even while serving a prison sentence for obstruction of justice. The alleged scheme took in more than $100 million, marketing lots in what supposedly would become a luxury development in Central America known by several names, including Sanctuary Belize, Sanctuary Bay, and The Reserve. The FTC alleged that the defendants misled consumers when selling these lots, lying about how risky investments in the development were, how the development was funded, what would be done with money paid for lots, what amenities the development would have, the timeframe those amenities would be built, consumers’ ability to resell lots, and Andris Pukke’s involvement. Several defendants settled prior to the January 2020 trial.

In late August 2020, the district court issued its verdict, finding in favor of the FTC. In early 2021, the court issued final orders against Andris Pukke, Peter Baker, Luke Chadwick, John Usher, and the corporate defendants, limiting what types of business they can engage in moving forward and entering a $120.2 million judgment against them. The defendants appealed and largely lost. During the appeal, Luke Chadwick settled, turning over certain assets and agreeing to a modified order further limiting the types of business he can engage in. After the appeal, the district court entered an order confirming that Andris Pukke, Peter Baker, and John Usher must turn over $120.2 million as well as the corporate defendants and their assets to compensate their victims.  In August 2023, the FTC sent approximately $10 million to consumer defrauded by the Sanctuary Belize investment scheme.

Type of Action
Federal
Last Updated
FTC Matter/File Number
X040009

Nerium International, LLC

The Federal Trade Commission sued the multi-level marketer Neora, LLC, formerly known as Nerium International, LLC, and its Chief Executive Officer, Jeffrey Olson, alleging that the company operates as an illegal pyramid scheme and falsely promises recruits they will achieve financial independence if they join the scheme. The lawsuit also alleged that defendants deceptively promote “EHT” supplements as an antidote to concussions and chronic traumatic encephalopathy caused by repetitive brain trauma, as well as Alzheimer’s disease and Parkinson’s disease. The FTC sought to permanently stop the defendants’ deceptive practices alleged in the complaint. In September 2023, the district court ruled against the FTC on its claims. In May 2024, the district court ruled that Neora could not recover its fees and expenses because the FTC’s position in this case was “substantially justified.”

Type of Action
Federal
Last Updated
FTC Matter/File Number
162 3099
Case Status
Closed

James D. Noland, Jr. (Success by Health)

A federal court granted the Federal Trade Commission’s request to temporarily shut down an alleged pyramid scheme known as “Success By Health,” and to freeze the assets of the company and its executives.

In May 2023, a federal court sided with the Federal Trade Commission, ruling that James D. Noland, Jr. illegally owned and operated two pyramid schemes—Success By Health (SBH) and VOZ Travel—in violation of the FTC Act and that Noland violated a previous federal court order barring him from pyramid schemes and from misrepresenting multilevel marketing participants’ income potential.

Type of Action
Federal
Last Updated
FTC Matter/File Number
X0100166
Case Status
Pending

RagingBull.com

The FTC alleged that the defendants fraudulently marketed investment-related services that they claimed would enable consumers to make consistent profits and beat the market. Instead, the FTC alleges that consumers—many of them retirees, older adults, and immigrants—have lost at least $137 million to the scam in just the last three years. The defendants claimed in their pitches that consumers don’t need a lot of time, money, or experience, and that the global coronavirus pandemic represents a great time to pay hundreds or thousands of dollars to learn their secret trading techniques, claiming in one ad that the pandemic “…might be the most exciting opportunity in decades!” The defendants also made claims like “Learn how you could DOUBLE or TRIPLE your account in One Week!” In March 2023, the FTC sent payments totaling more than $2.4 million to consumers in this case.

Type of Action
Federal
Last Updated
FTC Matter/File Number
2023073
X210014

Walmart, FTC v.

The Federal Trade Commission today sued Walmart for allowing its money transfer services to be used by fraudsters, who fleeced consumers out of hundreds of millions of dollars. In its lawsuit, the FTC alleges that for years, the company turned a blind eye while scammers took advantage of its failure to properly secure the money transfer services offered at Walmart stores. The company did not properly train its employees, failed to warn customers, and used procedures that allowed fraudsters to cash out at its stores, according to the FTC’s complaint. The FTC is asking the court to order Walmart to return money to consumers and to impose civil penalties for Walmart’s violations.

Type of Action
Federal
Last Updated
FTC Matter/File Number
182 3012
Case Status
Pending

Netforce Seminars, et al.

In a case first filed in January 2020, the FTC alleged that Success By Health and its executives James “Jay” Dwight Noland, Jr., Lina Noland, Scott A. Harris, and Thomas G. Sacca were operating an “instant coffee” pyramid scheme that used false promises of wealth and income to entice thousands of consumers to join.

The amended complaint alleges that the defendants were operating an additional pyramid scheme known as VOZ Travel. According to the amended complaint, the defendants sold consumers VOZ Travel “memberships” for at least $1,000 each. In exchange, they allegedly promised consumers access to a discount travel booking platform and the ability to earn rewards for recruiting other consumers to buy memberships. The complaint alleges that the defendants told consumers that some VOZ Travel members would be “making $1.53 [million] per year.”

Type of Action
Federal
Last Updated
FTC Matter/File Number
X010066

Warrior Trading, Inc., FTC v.

The Federal Trade Commission is cracking down on the Warrior Trading day trading investment scheme for making misleading and unrealistic claims of big investment gains to consumers. The FTC alleges that Warrior Trading and its CEO, Ross Cameron, used those claims to convince consumers to pay hundreds or thousands of dollars for a trading system that ultimately failed to pay off for most customers.

As a result of the FTC’s case, Warrior Trading will be required to pay $3 million to refund consumers and will be prohibited from making baseless claims about the potential for consumers to earn money using their trading strategies.

The Federal Trade Commission is sending payments totaling more than $2.9 million to 20,402 people who paid thousands of dollars for Warrior Trading’s investment programs. The company made misleading and unrealistic claims to sell a day trading “system” that failed to pay off for most customers.

Type of Action
Federal
Last Updated
FTC Matter/File Number
2023198
Case Status
Pending

Square One Development Group Inc., et al., U.S. and State of Wisconsin v.

The U.S. Department of Justice, on behalf of the Federal Trade Commission, and the Wisconsin Attorney General, filed suit against Consumer Law Protection and related companies, along with their owners and operators, Christopher Carroll, George Reed, Louann Reed, Scott Jackson, and Eduardo Balderas for scamming consumers—mostly older adults—out of more than $90 million in a massive timeshare exit scam.

Type of Action
Federal
Last Updated
FTC Matter/File Number
2123065
Case Status
Pending