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More Supplier Scrutiny The follow up NY Times story ?2 Firms Tied to Phone Lists Will Review Their Policies? on direct marketing suppliers involved in supporting fraudulent marketers highlights the current regulatory quagmire suppliers find themselves in being placed in the position of policing their own clients.
NY Times Feature Story Reinforces Supplier Due Diligence Obligations Sunday's New York Times front page feature story - Bilking the Elderly, With a Corporate Assist - demonstrates why suppliers must know their customer and undertake due diligence regarding the underlying marketing offer. The article blames those who supplied the fraudsters with mailing lists and those who processed the payments for the acts of unscrupulous markters. As we have previously written, regulators continue to focus on going after legitimate suppliers who assist those (knowingly or even unknowingly) are violating the law.
FTC Action Against International Sweepstakes Reporter Mailings
The FTC recently announced a settlement with sweepstakes reporter defendants involving international mailings highlights the FTC’s assertion in litigation that it has jurisdiction over marketing directed at foreign residents, despite the fact that such a position has been rejected by some courts and the government otherwise seeks to have Congress grant it authority over such foreign activities.
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