The FTC settled allegations against Stormy Wellington, a high-level multilevel marketing (MLM) participant, for using false and unsubstantiated earnings claims to recruit new members for Total Life Changes and Farmasi MLMs. The stipulated final order prohibits Wellington from making deceptive earnings representations, requires written substantiation of all earnings claims, and mandates notification to her downline participants about the order’s prohibitions. No monetary penalty was imposed.
The stipulated order prohibits Wellington from misrepresenting potential or actual participant earnings, reasons for lack of compensation, or other material facts about MLM business ventures, including via images of luxury purchases or travel. She must substantiate all earnings claims with written evidence and provide such evidence to interested potential participants upon request. Additionally, she is required to notify all her downline MLM participants about the order’s prohibitions on deceptive earnings claims.
In-house legal teams at MLM companies, direct selling firms, or businesses using independent contractors for recruitment should review participant, influencer, and recruitment vendor agreements to prohibit deceptive or unsubstantiated earnings claims. Clauses governing income representations must require written substantiation of all earnings claims, limit statements to actual participant earnings data, and ban misleading implications of guaranteed income. Teams should also add clauses requiring participants to notify their downline of compliance orders, align agreements with mandatory income disclosure requirements, and include indemnification for deceptive earnings claims made by contractors. Marketing and advertising agreements with high-level recruiters should explicitly ban false earnings promises and require retention of substantiation records.
Entity
Stormy Wellington
Industry
OtherOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2026/04/ftc-takes-action-against-high-level-mlm-participant-who-deceived-workers-about-amount-money-they-can
2523145wellingtoncomplaint
https://www.ftc.gov/system/files/ftc_gov/pdf/2523145wellingtoncomplaint.pdf
Wellington Order
https://www.ftc.gov/system/files/ftc_gov/pdf/Wellington-Order.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Stormy Wellington"
"April 13, 2026"
"used false or baseless earning claims to recruit workers, most of whom did not earn any money from the venture."
"Wellington will be prohibited from misrepresenting or assisting others in misrepresenting how much money others can earn from various business ventures."
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$1.9M
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