4 Tips to Keep Your Online Brand Ambassadors ‘FTC-Free’

Today, many companies recruit affiliate marketers—or paid brand advocates—to promote their products or services via social platforms in return for a commission. These advocates can include individual bloggers or brand ambassadors, as well as affiliate management agencies that employ associates to blog and post hyperlinks. 

If you work for an organization that recruits paid advocates, or if you recruit them for a client, there is much you need to know to avoid action from the FTC.  Here are four tips for managing brand ambassador conduct:

  1. Companies and/or their agencies should have an agreement with their paid advocates that instructs their affiliates to make appropriate disclosures when endorsing their products or services. But that is not enough…

  2. Establish reasonable monitoring programs for your online advocates to verify that they are making the appropriate disclosures.

  3. Ensure that your advocates’ disclosures are clear and conspicuous, and not buried behind general info or poorly labeled hyperlinks.

  4. Consider consulting with counsel on how to establish reasonable monitoring programs for paid brand advocates.

Unfortunately, there is no one-size-fits-all model. But failure to properly address your advocates could have serious consequences. 


Michael Lasky and Allison Fitzpatrick are partners at the law firm Davis & Gilbert LLP. You can reach Michael at MLasky@dglaw.com, and Allison at 
AFitzpatrick@dglaw.com.

This article was adapted from PR News' Digital PR Guidebook, Vol. 4. This and other guidebooks can be ordered at the PR News Press online store.