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On March 5, the Director of the FTC’s Bureau of Consumer Protection Christopher Mufarrige delivered remarks outlining several enforcement priorities for the agency’s consumer protection work, including enforcement of the Better Online Ticketing Sales Act (BOTS Act), efforts to address fraud in the U.S. payment system, and actions targeting deceptive subscription practices under the Restore Online Shopper’s Confidence Act (ROSCA).
The remarks highlighted three areas where the FTC is currently focusing enforcement resources:
- Ticketing enforcement under the BOTS Act. The FTC has recently brought actions alleging that ticket brokers used software tools, proxy services, and large numbers of false purchasing accounts to circumvent ticket purchase limits imposed by primary ticket sellers. The FTC also alleged that certain platforms involved in both primary ticket sales and resale markets knowingly facilitated the resale of tickets obtained through such circumvention practices.
- Fraud prevention through payment intermediaries. The FTC emphasized a strategy of targeting “upstream” entities in the payments ecosystem that allegedly ignore red flags when onboarding or servicing high-risk merchants. According to the agency, payment processors, payment facilitators, and merchant-of-record platforms play a critical role in maintaining the integrity of payment networks by properly screening merchants and monitoring transaction activity.
- Subscription and negative-option practices under ROSCA. The FTC stated that it continues to bring enforcement actions against companies that enrolled consumers in recurring subscription plans without clear disclosures, express informed consent, or simple cancellation mechanisms. These cases often allege violations of Section 5 of the FTC Act, which prohibits unfair or deceptive acts or practices.
In discussing these initiatives, the FTC framed its consumer protection role as “market-reinforcing,” emphasizing that enforcement efforts are intended to ensure consumers receive accurate information and retain meaningful control over purchasing decisions.
Putting It Into Practice: The FTC continues to advance consumer protection priorities through both rulemaking and enforcement. Companies operating in consumer-facing markets should continue monitoring FTC developments and adjust compliance practices as necessary.
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