Payments Pros – The Payments Law Podcast
Aug 6, 2026 · 18 min · 10 segments
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…
Today, I am going to discuss a recent lawsuit that was filed by the Federal Trade Commission over alleged unlawful subscription schemes.
Even though there were no payment processors, banks, money transmitters, none of them were sued, it still has significant payments-related implications.
And in this particular case, the FTC obtained a temporary restraining order and asset freeze until the parties could have a full hearing on the issues.
So today we're going to discuss the allegations and the complaint, what the temporary restraining order prevents the defendants from doing during the course of the lawsuit, and what this means overall in the payments industry.
But once again, this is yet another example of the FTC continuing to bring investigations and enforcement actions against merchants that affect the payments industry.
And here, in the summary of what's going on, we're going to touch on Bank Secrecy Act compliance, and as I mentioned before, the FTC Act and ROSCA.
And in particular, the issues in this case concerned advertising that may be deceptive, recurring payments when...
The recurring nature of the payments were allegedly not disclosed to consumers.
Cancellation, like when a merchant makes it too hard for a consumer to cancel recurring payments.
And we are also going to talk about the extensive injunctive relief that the FTC has already received in this case.
Today, I am going to discuss a recent lawsuit that was filed by the Federal Trade Commission over alleged unlawful subscription schemes.
Even though there were no payment processors, banks, money transmitters, none of them were sued, it still has significant payments-related implications.
And in this particular case, the FTC obtained a temporary restraining order and asset freeze until the parties could have a full hearing on the issues.
So today we're going to discuss the allegations and the complaint, what the temporary restraining order prevents the defendants from doing during the course of the lawsuit, and what this means overall in the payments industry.
But once again, this is yet another example of the FTC continuing to bring investigations and enforcement actions against merchants that affect the payments industry.
And here, in the summary of what's going on, we're going to touch on Bank Secrecy Act compliance, and as I mentioned before, the FTC Act and ROSCA.
And in particular, the issues in this case concerned advertising that may be deceptive, recurring payments when...
The recurring nature of the payments were allegedly not disclosed to consumers.
Cancellation, like when a merchant makes it too hard for a consumer to cancel recurring payments.
And we are also going to talk about the extensive injunctive relief that the FTC has already received in this case.
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