The Federal Trade Commission (FTC) sent letters to 10 companies—whose identities were not publicly disclosed—on December 22, 2025, warning them about potential violations of the Consumer Reviews Rule. The Rule, which took effect in October 2024, targets deceptive online review and testimonial practices. These warning letters mark the FTC’s first public enforcement action under the Rule and, according to FTC Bureau of Consumer Protection Director Christopher Mufarrige, underscore the agency’s commitment to enforcement of the Rule.

The Consumer Reviews Rule prohibits the use of fake reviews or reviews that misrepresent a reviewer’s experience with a product or service, as well as reviews that fail to disclose insider or familial connections to the company whose product or service is being reviewed. The Rule also bans conditioning incentives on reviews that express a specific sentiment, suppressing negative reviews, the use of so-called “company-controlled review websites,” and misrepresenting social media indicators of influence. Violations can result in civil penalties of up to $53,088 per violation.

According to the letter template, the FTC’s warnings were based on consumer complaints and information provided by the companies themselves. Examples of prohibited practices that recipients of the letter may have engaged in include compensating employees for obtaining five-star reviews from friends and family and soliciting reviews from individuals who had no actual experience with the company’s products or services. While these letters do not constitute formal findings of violations, the FTC urges recipients to immediately cease any non-compliant practices and confirm remediation efforts, warning that continued non-compliance may lead to federal lawsuits and substantial monetary penalties. Based on the template, recipients have five business days to provide the FTC with a plan to ensure compliance with the Rule going forward.

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Photo of Jehan Patterson Jehan Patterson

Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection…

Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection matters.

Jehan is a member of the Advertising and Consumer Protection Investigations group. She represents corporate and individual clients in consumer protection investigations and litigation by the FTC and state Attorneys General and state financial regulators. She advises clients on consumer protection considerations relating to generative and agentic artificial intelligence, state and federal laws governing autorenewal programs, sustainability and other environmental claims, the FTC’s Made in USA rule, the USDA’s National Organic Program, adtech, and other advertising matters. Jehan also represents clients in complex civil litigation involving consumer protection claims.

Before joining Covington, Jehan was a Senior Litigation Counsel in the Office of Enforcement at the Consumer Financial Protection Bureau, where she led investigations into numerous providers of consumer financial products and services for violations of federal consumer financial laws and regulations, including the Consumer Financial Protection Act’s prohibition against unfair, deceptive, and abusive acts and practices.

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Photo of Alexandra Remick Alexandra Remick

Alexandra Remick is a member of the Advertising and Consumer Protection Investigations Group. Her practice focuses on regulatory and compliance matters related to consumer protection. She has experience advising clients on topics including endorsements, social media influencers, native advertising, automatically renewing subscriptions, consumer…

Alexandra Remick is a member of the Advertising and Consumer Protection Investigations Group. Her practice focuses on regulatory and compliance matters related to consumer protection. She has experience advising clients on topics including endorsements, social media influencers, native advertising, automatically renewing subscriptions, consumer reviews, and claim substantiation in a variety of contexts. She frequently provides advice on specific advertising compliance questions and works with companies on developing internal advertising compliance policies. She has also represented multiple clients in FTC investigations involving consumer protection issues, has conducted regulatory due diligence on multiple transactions, and has drafted comments on multiple rulemakings.

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Photo of Taylor Kay Taylor Kay

Taylor Kay is an associate in the firm’s Washington office. She is a member of the Advertising and Consumer Protection Investigations Practice Group and advises clients on a range of matters including endorsements/influencers, claim substantiation, and environmental/”green” marketing. She has also worked on…

Taylor Kay is an associate in the firm’s Washington office. She is a member of the Advertising and Consumer Protection Investigations Practice Group and advises clients on a range of matters including endorsements/influencers, claim substantiation, and environmental/”green” marketing. She has also worked on FTC investigations and regulatory due diligence matters. Taylor also maintains an active pro bono practice with focuses on freedom of speech and LGBTQ+ issues.

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