David Klafter, Senior counsel at Pershing Square, wrote an extensive letter to Herbalife’s new chief of compliance, Pamela Jones Harbour. Before diving into the letter, the basics: Pam Harbour was a former FTC Commissioner. The FTC is led by 5 commissioners, she was one of them for 7 years. She recently took a position as […]
In my opinion, compliance departments should be designed to serve two important functions: education and protection. First and foremost, they exist to train distributors of the proper behavior when marketing the product and income opportunity. When the sales force is properly educated, it leads to good behavior in the field, which leads to fewer complaints and better longevity for the company. Secondly, when their education efforts fail with certain people, compliance departments exist to levy penalties to protect the companies from legal troubles.
The Federal Trade Commission has filed a complaint to stop LeanSpa, a weight loss company that has allegedly used fake news websites from affiliate marketers to promote its acai products. LeanSpa parties apparently used affiliate marketers to drive interest to their program. Allegedly, the affiliates used “fake news sites” to fein credibility about the products […]