The Federal Trade Commission's Labor Task Force - a unit formed last year under Chairman Andrew Ferguson to target unfair labor practices - published a new blog post this week summarizing its recent enforcement cases and the lessons business owners should take from them.

The headline examples are multi-level marketing companies. Four cases from April 2026 involving LifeWave, Total Life Changes, Forever Living, and a company called International Markets Live (also known as IM Mastery Academy) resulted in judgments totaling close to $800 million and permanent bans on making earnings claims.

But the FTC did not publish this summary just to recap past cases. It published it as a warning.

And the warning is broader than MLMs.

What the FTC Is Actually Saying

Here is the core issue: businesses that use income or earnings claims to attract participants, recruits, affiliates, or customers are now on notice that those claims need to be backed up - with real data, accounting for real expenses, reflecting what most participants actually earn.

Not what the top 1% earns. Not what someone made in their best month. Not a vague promise about "unlimited income potential."

The FTC's new standard - established through these cases and now formalized in its blog post - is that any earnings claim must account for the typical participant's experience, including their costs, and must not overstate what most people actually receive.

"Despite claiming recruits could earn hundreds of thousands - and even millions - of dollars, the MLMs' own income disclosure statements showed that most people made little or no money," the FTC wrote in summarizing the Wellington and Merritt cases.

That language - "the company's own income disclosure statements showed" - is important. The FTC is using companies' own data to prove misrepresentation.

Why This Goes Beyond MLMs

Multi-level marketing is the obvious target here. But the FTC's jurisdiction and the logic of this enforcement extends to any business model that uses earnings claims to recruit participants or motivate purchasing.

Think about:

Online courses and coaching programs. "Enroll in my program and make $10,000 a month." If you make that claim - in an ad, on a landing page, in a sales email - and most students do not come close to that number, you have a problem. The FTC has targeted these programs before and the Labor Task Force makes them more visible.

Affiliate and referral programs. If you recruit affiliates with income projections, those projections are now subject to the same standard. Claiming "our top affiliates earn $5,000 a month" while the median affiliate earns $50 is the kind of gap that gets attention.

Franchise-adjacent business opportunities. Any model where someone pays to participate with the expectation of earning money back - and where you make representations about what that looks like - falls in this category.

Gig platforms that market earning potential. "Earn up to $X per hour" claims have always been risky. The "up to" qualifier does not provide as much protection as companies assume.

The Practical Standard the FTC Is Enforcing

The FTC is not saying you cannot make earnings claims. It is saying your claims have to hold up under scrutiny. Specifically:

1. The claim must be truthful - meaning it reflects what participants actually earn, not just what is theoretically possible.
2. The claim must account for expenses - if someone spends $500 to earn $600, the $600 gross is not an honest representation of what they make.
3. The claim must be substantiated - you need actual data to support it, not testimonials from outliers.
4. The claim must be non-misleading in context - a footnote disclosing poor average results does not neutralize a prominent headline claiming extraordinary earnings.

The penalty for getting this wrong: civil penalties above $50,000 per violation, in addition to injunctions, asset freezes, and in some of the recent cases, the loss of personal assets.

What to Do If This Applies to Your Business

If you run any kind of program where you tell people how much they could earn by participating - stop and audit what you are saying.

Pull your actual earnings data. Calculate the median result, not the mean, and not the best-case scenario. If your median participant earns close to what you are claiming - you are probably fine. If the gap is wide, the claims need to change.

The FTC has shown it will use a company's own disclosure documents as evidence. If you have income disclosure statements, product income reports, or affiliate payout summaries, those documents are a mirror. Read them the way the FTC would.

If you are a small business offering an affiliate program, a referral bonus structure, or any kind of "join us and earn" pitch, it is worth a 30-minute audit of your marketing materials with this standard in mind. It is a much cheaper conversation than the one that starts with a complaint letter from the FTC.

A Note for Spanish-Speaking Business Owners

The FTC regularly targets Spanish-language marketing channels because research has consistently shown that immigrant communities - particularly recent immigrants unfamiliar with US consumer protection laws - are disproportionately recruited into high-risk income opportunity schemes. The same enforcement standards apply regardless of language.

If you market an income opportunity in Spanish, the FTC's guidance applies. If someone approaches you in Spanish with an extraordinary income promise, this enforcement pattern is worth knowing about.

The FTC blog post is available at ftc.gov. It is written in plain English and is worth reading in full if any of this applies to your business.

Alex Rivera covers policy, regulation, and government actions affecting small business owners - in English and Spanish. Sources: FTC Labor Task Force blog post, June 2026, FTC Wellington case press release, FTC Forever Living order.