The most recent FTC action in Watchword's record is from June 2, 2026: Amare Global Holdings Inc. (complaint filed). The summary and the FTC’s own source are below.
This page lists the FTC’s actions on influencer and creator content in Watchword’s record, the FTC guidance brands ask about most, and the latest US actions on influencer and creator marketing from the FDA, advertising self regulatory bodies, and the courts. Every item links to its source.
Built from Watchword’s risk record: 63 entries since 2023. Last reviewed October 19, 2026. Last new entry October 12, 2026. A filed lawsuit or complaint is an allegation, not a finding. NAD, CARU and ERSP are industry self regulatory bodies, not government agencies. This page summarizes public records and is not legal advice.
The FTC sued multilevel marketer Amare Global in federal court in the Central District of California, alleging that the company and its brand partners advertised Kids Happy Juice and related supplements on Instagram, TikTok, YouTube, and Facebook with unsubstantiated claims to treat depression, anxiety, and ADHD, and that the company made deceptive earnings claims to people it recruited to join. These are allegations; no finding has been made.
FTC staff sent warning letters to two trade associations and 12 registered dietitians and other online health influencers over Instagram and TikTok posts promoting the safety of aspartame or the consumption of sugar-containing products. FTC stated the letters identified what appeared to be paid posts that either did not disclose a material connection or had disclosures that may be inadequate, and noted that recipients could face civil penalties of up to $50,120 per violation for future failures to disclose unexpected material connections.
The FTC announced that three high-level doTERRA distributors agreed to court orders requiring each to pay a $15,000 civil penalty. In complaints filed by the Department of Justice on the FTC's behalf under the FTC Act and the COVID-19 Consumer Protection Act, the government alleged that the distributors claimed in a series of webinars in early 2022 that doTERRA essential oils and dietary supplements could treat, prevent, or cure COVID-19.
These FTC actions are about reviews, testimonials and endorsements in general rather than creator content specifically, so they are not in the risk record. Each links to the FTC’s own announcement.
For what the FTC says about disclosures on creator videos, see the TikTok Shop creator disclosure guide. For the wider picture, see Creator marketing risk: a guide for brands.
The 12 most recent actions in the record by the FDA, private plaintiffs and advertising self regulatory bodies.
FDA issued a warning letter stating that HClear for him and FemiClear Genital Herpes Symptoms were unapproved new drugs. The letter cites the company's website and its Facebook and Instagram accounts, which it says direct consumers to the website to buy the products, including Facebook posts dated September 10, 2024 and January 29, 2026 and an Instagram post dated April 4, 2025.
FDA issued a warning letter stating that Herstat GST, labeled as a 'Genital Sore Treatment,' was an unapproved new drug. The letter cites the company's websites and its Facebook and Instagram accounts, which it says direct consumers to the website to buy its products, including an October 12, 2022 post on both accounts describing the product as providing relief from the symptoms of genital sores.
A parent and a minor filed a proposed class action (Vettel v. Sephora USA, Inc., No. 3:26-cv-09653, N.D. Cal.) alleging that Sephora sells more than 1,600 products containing ingredients the complaint calls unsuitable for children, described as a majority of the skincare products offered on Sephora.com, without age related warnings at the point of sale. The complaint also describes Sephora's paid influencer program and the Sephora x TikTok Incubator Program, established with TikTok and the agency Digitas, and alleges that brands sold through Sephora sent complimentary skincare and curated packages to young social media creators. These are allegations; no finding has been made.
A consumer filed a proposed class action (Moeller v. Blockratize, Inc., No. 1:26-cv-03083, D.D.C.) alleging that Polymarket paid content creators to film betting videos on copies of its website that ran on the company's own servers, so that the bets and wins shown were not real, and that it instructed the creators not to disclose that they were paid. These are allegations; no finding has been made.
According to a September 29, 2026 summary by the law firm Kelley Drye, CARU, as part of its routine monitoring, 'found posts from kid influencers that promoted Coco Vida clothing on Instagram,' and although the company had hired the influencers to post content, CARU was concerned that the influencers did not clearly disclose their connection to the company. Kelley Drye reports that CARU recommended Coco Vida ensure that influencers clearly disclose their connection to the company 'in a way that is understandable to children' and that the content is readily identifiable as advertising, and that it implement procedures to monitor influencers. The summary does not state whether Coco Vida agreed to comply or appealed, and no public decision summary for this case could be found on the BBB National Programs website. CARU is an industry self regulatory body, not a government agency, and its recommendations are not legal findings.
FDA issued a warning letter stating that umbilical cord and exosome products sold under the ReBella name were unapproved new drugs and unlicensed biological products, citing the company's websites and its YouTube, TikTok, Instagram, and Facebook accounts, including a March 5, 2026 YouTube video in which an employee showed vials of the products to a patient and described the exosomes as 'very anti-inflammatory.'
The National Association of Consumer Advocates sued Polymarket, its CEO, and its chief marketing officer in D.C. Superior Court (No. 2026-CAB-004388) under the District's Consumer Protection Procedures Act, alleging that influencers were paid to promote the platform without disclosure, that creators filmed bets on a simulated version of the platform, and that the company paid clippers to make and post short clips of its ads with instructions not to make them feel like ads. These are allegations; no finding has been made.
FDA issued a warning letter stating that a Prostatitis Remission Cream was an unapproved new drug and misbranded. The letter cites the company's website and its TikTok Shop storefront as places the product was offered and copies TikTok's Global Head of Trust and Safety.
A consumer filed a proposed class action (Lupea v. Gymshark USA, Inc., No. 1:26-cv-05073, S.D.N.Y.) alleging that Gymshark had influencers on Instagram, YouTube, and TikTok promote its apparel without disclosing that they were paid, and that exclusivity arrangements with those influencers were not disclosed to consumers. These are allegations; no finding has been made.
NAD's inquiry into Kalshi's advertising included whether 'material connections between Kalshi and influencers or affiliates were clearly and conspicuously disclosed in social media advertising' and 'whether Kalshi takes adequate steps to ensure compliance with the Federal Trade Commission's Guides Concerning the Use of Endorsements and Testimonials in Advertising.' The decision summary states that 'Kalshi declined to participate in the NAD self-regulatory process,' so NAD made no recommendations, and that NAD 'will refer this matter to the appropriate regulatory authorities, including relevant state Attorneys General, and to the platforms on which the advertising appeared...' The summary names no platform. No government action has been taken: the referral is NAD's own and is prospective. NAD is an industry self regulatory body, not a government agency, and a referral is not a legal finding.
Shenzhen Zhihuida Technology Co., Ltd. and Gaosto Ltd. voluntarily dismissed with prejudice their lawsuit against PetPivot Inc., two TikTok accounts, two individuals, and an unnamed defendant (No. 4:26-cv-00054, E.D. Tex.), after the parties jointly asked the court to stay the case pending settlement. The docket records the notice of voluntary dismissal on May 15, 2026, and the court's acknowledgement on May 19, 2026, which recounts that 'Plaintiffs file this notice voluntarily dismissing, with prejudice, all their claims filed against Defendants herein.' No finding was made. The docket does not state that the case settled or report any terms.
FDA issued a warning letter stating that the SaniiSwab nasal product was an unapproved new drug and misbranded, citing Facebook and Instagram posts about preventing illness and stopping the spread of germs during flu season, and a website statement that the product was 'FDA OTC approved,' which FDA said was false or misleading because the product is not the subject of an approved application.
See all 63 entries, with filters, in the full record
The most recent FTC action in Watchword's record is from June 2, 2026: Amare Global Holdings Inc. (complaint filed). This page lists it with a summary and a link to the FTC's source, and updates every week with Watchword's record. The FTC also finalized orders in July 2026 against TruHeight and Publishing.com that address reviews and endorsements more broadly; both are listed on this page.
The most recent FTC action in Watchword's record that involves influencer disclosures is from November 15, 2023: American Beverage Association, The Canadian Sugar Institute, and 12 registered dietitians and other online health influencers (warning letter). The FTC's Endorsement Guides, updated in 2023, are still the main FTC guidance on disclosing a material connection, such as a payment, free product or commission. This page lists the FTC's disclosure actions with their sources.
Watchword's record lists 3 FTC actions involving influencer or creator content since 2023, most recently on June 2, 2026. Over the same period it lists 60 more by other regulators, advertising self regulatory bodies and private plaintiffs. The FTC actions are listed on this page, and the full record, with a source for every entry, is at usewatchword.com/risk.
The FTC's guidance says creators should disclose a material connection to a brand, such as a commission, free product, or payment. Watchword's TikTok Shop creator disclosure guide covers what the FTC and TikTok say about it.
The FTC's guidance for companies with influencer programs says the company is ultimately responsible for what others do on its behalf.
Watchword reviews new FTC and FDA actions, state attorney general announcements, court filings, and NAD and CARU decisions each week. This page updates whenever the record does.
No. This page summarizes public records and public guidance. A filed lawsuit or complaint is an allegation, not a finding. For decisions about your program, talk to your counsel.