FTC Order to Prohibit Forever Living and its Operators from Deceiving Consumers about Potential Earnings
Operators of multilevel marketing (MLM) company Forever Living will be permanently prohibited from making deceptive earnings claims to resolve Federal Trade Commission allegations that the company deceived consumers into believing that they could earn profits from the venture when the vast majority of participants made little or no money.
In its complaint, the FTC alleged that Forever Living Products International LLC, its CEO Gregg Maughan, and its President Aidan O’Hare, as well as Forever Living.com LLC, used deceptive earnings claims to attract new participants called Forever Business Owners (FBOs), most of whom made no money or even lost money. The company and its operators claimed participants could make money by selling Forever Living’s health and wellness products either in person or online through the company’s website and by recruiting new participants who would do the same.
“Today’s complaint alleges that Forever Living deceived prospective workers with false and unsubstantiated earnings claims. Forever Living misled workers with promises of substantial income that, in reality, bore little to no resemblance to what participants actually earned,” said Christopher Mufarrige, Director of the FTC’s Bureau of Consumer Protection. “Deceptive earnings claims do not just mislead workers—they divert workers away from genuine, income-generating jobs. The FTC will not hesitate to take action against companies that deceive workers with claims of false earnings that they know few, if any, will achieve.”
Through in-person meetings and conferences, internet and social media posts and videos, and print materials, Forever Living used images of luxury cars and giant checks, and claims of profits ranging from extra income to replacing a full-time job to tout the potential earnings from selling its products or recruiting new FBOs, the FTC alleged. For example, in an online marketing video O’Hare told viewers, “We will be paying millions in bonuses next year. The only question is, whose name goes on that check?”
The FTC alleged that most FBOs did not make any money and many lost money after factoring in expenses such as the cost of shipping products. In fact, according to company data, in each of the last five years at least 77% of FBOs who purchased, sold or recruited during the year did not receive any compensation. Even after two full years as FBOs, more than 89% of new participants had not received enough income from Forever to recoup their initial $300-plus start-up cost.
The FTC also alleged that, for years, the company’s public income disclosure statements falsely implied that everyone who had chosen to pursue the MLM income opportunity was making money, and that others who “joined” Forever only wished to purchase products “at a discounted price” and had “elected not to participate in [the] Marketing Plan.” In truth, Forever knew that nearly 90% of FBOs had received no income from Forever, and it had no basis for suggesting they were not trying to make money.
The FTC further alleged the company’s training materials encourage FBOs to tout Forever Living as a flexible way to earn extra money in order to recruit new participants. For example, in one training video, FBOs were told to show pictures of cars they may have received from Forever Living’s incentive program or destination events they attended and to tout that “this is a business where you can earn a lot of income.” Forever Living also has misled FBOs with claims that they are likely to earn money based on purchases or sales made by FBOs they recruit, known as their “downline,” when the company’s data shows that less than 7% of FBOs received income from the sales and purchases made by their downline FBOs, according to the complaint.
Under the proposed order settling the FTC’s allegations, Forever Living, Maughan and O’Hare:
Must have substantiation for any earnings claims and must provide substantiation for any earnings claim they make if a U.S. consumer requests it;
Must not misrepresent that participants have made, will or are likely to make or receive earnings (or any particular amount of earnings);
Must not misrepresent the reasons participants do not make money in Forever’s MLM, including claims that participants who do not make money aren’t trying to;
Must not misrepresent that participants are likely to recruit others into their downline; and
Must not misrepresent other facts about the MLM opportunity that would be important to consumers.
The Commission vote authorizing the staff to file the complaint and stipulated final order was 2-0. The FTC filed the complaint and final order in the U.S. District Court for the District of Arizona.
NOTE: The Commission files a complaint when it has “reason to believe” that the named defendants are violating or are about to violate the law and it appears to the Commission that a proceeding is in the public interest. Stipulated final orders have the force of law when approved and signed by the District Court jud
The Federal Trade Commission is taking action against a high-level participant in a multilevel marketing (MLM) company over allegations she used false or baseless earning claims to recruit workers, most of whom did not earn any money from the venture.
The FTC alleged in a complaint that Stormy Wellington, who has been a high-level participant in two different MLMs, used deceptive earnings claims to recruit new members to Total Life Changes (TLC) and, more recently, Farmasi.
“Today’s actions make clear that the FTC will go after individuals who deceive consumers trying to earn a living,” said Christopher Mufarrige, Director of the FTC’s Bureau of Consumer Protection. “This case highlights the FTC’s ongoing efforts to protect workers from recruiters who misrepresent potential earnings.”
In MLMs, individual participants market and sell the MLM’s products or services and recruit new participants, who themselves will sell the MLM’s products or services and recruit new participants. Wellington was a high-level participant who benefitted from recruiting new members using allegedly false or misleading promises of earning significant income.
In YouTube videos and social media posts, Wellington tried to entice new participants by claiming they could make hundreds of thousands and even millions of dollars, according to the FTC’s complaint. For example, Wellington posted a video on her Facebook page promoting TLC that included a caption stating, “I will help 1000 families make 5-7 figures in the next 90 days to 12 months!”
Wellington spent a decade at TLC, which sells nutrition, wellness, and skincare products, before leaving in August 2025 to join Farmasi, which sells make-up, skincare, and health and wellness products. She allegedly promised new recruits to Farmasi that they can earn big money, saying, “I’m telling you right now, no less than six figures, no less. Repeat that to me. No less than six figures,” and that she will make “60 new millionaires in 2026.”
Despite these claims, in both MLMs most participants made little or no money. In TLC’s income disclosures posted to its website, TLC states that 76.8% of active participants (23,124 people) did not earn any compensation in calendar year 2023, and that, at most, 0.4% of all active participants (113 people) earned more than $5,000. Similarly, Farmasi’s income disclosure statement posted to its website shows that, in 2023, fewer than 1% of active participants earned income in the six-figure range the FTC alleges Wellington promised.
In a proposed order settling the FTC’s allegations, Wellington will be prohibited from misrepresenting or assisting others in misrepresenting how much money others can earn from various business ventures. This includes prohibiting Wellington from misrepresenting:
Expressly or by implication, including through images of homes, vehicles, purchases, or travel, earnings that participants will or are likely to make;
The amount of earnings that she or other participants have actually earned;
The reason participants do not earn substantial compensation; and
Any other fact material to consumers concerning the business venture.
In addition, Wellington will be prohibited from making any representation, expressly or by implication, regarding the amount of earnings that a participant can expect to earn unless: it is not misleading, she can substantiate in writing the earnings claim when it is made, and she can provide evidence upon request to any individual who expresses an interest in becoming a participant. Wellington also will be required to notify her downline participants about the order’s prohibition on making deceptive and unsubstantiated earning claims.
The Commission vote to authorize the staff to file the complaint and stipulated final order was 2-0. The matter was filed in the U.S. District Court for the Southern District of Florida.
NOTE: The Commission files a complaint when it has “reason to believe” that the named defendants are violating or are about to violate the law and it appears to the Commission that a proceeding is in the public interest. Stipulated final orders have the force of law when approved and signed by the District Court judge.
The lead staff on this matter include Claire Wack and Melissa Dickey in the FTC’s Bureau of Consumer Protection.
The Federal Trade Commission has obtained a temporary restraining order against an alleged student loan debt relief scheme and its operators over allegations they pretended to be affiliated with the U.S. Department of Education or loan servicers and falsely promised student loan debt relief that did not exist in exchange for illegal upfront fees.
The FTC’s complaint against NERD Solutions Inc., ED REF Inc., and their operators Natalie Rodriguez and Pablo Ortiz alleges that, since at least February 2022, the defendants illegally marketed student loan debt relief services by cold calling consumers, thousands of whom are on the National Do Not Call list, and pretending to be affiliated with the U.S. Department of Education or consumers’ actual loan servicers.
The complaint notes that the defendants then used false claims of student loan forgiveness to lure consumers into paying illegal upfront monthly fees as high as $1,400. The complaint also alleges the operators of the scheme have collected at least $8.8 million from consumers that are already burdened with massive student loan debt.
The defendants are charged with violating the FTC Act, the Telemarketing Sales Rule, the Impersonation Rule, and the Gramm-Leach-Bliley Act.
FTC staff would like to thank the Ohio Office of the Attorney General for their substantial assistance in the investigation.
The Commission vote authorizing the staff to file the complaint was 2-0. The U.S. District Court for the Central District of California entered a temporary restraining order in the case on April 13, 2026.
NOTE: The Commission files a complaint when it has “reason to believe” that the named defendants are violating or are about to violate the law and it appears to the Commission that a proceeding is in the public interest. The case will be decided by the court.