The Federal Trade Commission (FTC) sent warning letters to 13 data brokers reminding them of their obligations under the Protecting Americans’ Data from Foreign Adversaries Act (PADFAA). PADFAA prohibits data brokers from selling or providing sensitive personal data about Americans to foreign adversaries such as China, Russia, Iran, and North Korea. The letters warn that violations could result in civil penalties of up to $53,088 per violation and urge companies to review their business practices for compliance.
In-house legal teams should review all vendor and data processing agreements where the company acts as a data broker or shares data with third parties, particularly those involving international transfers. Specific clauses to scrutinize include data sharing/transfer provisions, definitions of sensitive data, compliance with laws, prohibited destination lists, and audit rights. Changes may be needed to explicitly incorporate PADFAA's prohibitions on selling or providing sensitive personal data to foreign adversaries (China, Russia, Iran, North Korea), update data classification schemas to match PADFAA's definition (including health, financial, biometric, geolocation, etc.), add representations and warranties regarding non-disclosure to adversarial nations, and implement enhanced monitoring and termination rights for potential violations.
Entity
Data Brokers
Industry
Data BrokerOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2026/02/ftc-reminds-data-brokers-their-obligations-comply-padfaa
military padfaa warning letter template
https://www.ftc.gov/system/files/ftc_gov/pdf/military-padfaa-warning-letter-template.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
CalPrivacy issued Enforcement Advisory No. 2025-01 to remind data brokers of their annual registration obligations under California's Delete Act, including disclosing all trade names and websites and registering independently rather than through a parent company. The advisory warns that failures to comply may result in administrative fines of $200 per day, plus fees and recovery costs. It also highlights the upcoming Delete Request and Opt-Out Platform (DROP) launching January 1, 2026.
The California Privacy Protection Agency (CalPrivacy) announced the creation of a Data Broker Enforcement Strike Force to investigate privacy violations by data brokers. The strike force will focus on compliance with the Delete Act's registration requirement and the CCPA, building on previous enforcement actions. This initiative aims to hold data brokers accountable and protect Californians' personal information.
The California Privacy Protection Agency (CalPrivacy) announced the creation of a Data Broker Enforcement Strike Force to investigate privacy violations by data brokers under the CCPA and Delete Act. The strike force will focus on compliance with registration requirements and other obligations, building on previous enforcement actions to increase accountability.
The FTC, Utah, and Nevada sued Lens.com Inc., alleging that it advertised artificially low contact lens prices while hiding mandatory checkout charges and misleading consumers about its AutoRefill subscription. The complaint seeks to stop the alleged practices; the court has not yet decided the case, and no penalty or remedy has been imposed.
The FTC issued an advance notice of proposed rulemaking seeking public comment on whether ad-optimization tools offered by online platforms may help scammers impersonate businesses and government agencies. This is a proposed regulatory inquiry, not an enforcement action against a named company; no penalty or remedy was imposed.
$2.5B
A federal court approved a revised order in the FTC's Amazon Prime case under which Amazon will accelerate and expand redress payments under the September 2025 $2.5 billion settlement, which resolved allegations that Amazon enrolled millions of consumers in Prime subscriptions without their consent and knowingly made cancellation difficult. More consumers now qualify for refunds, the maximum payment cap rises from $51 to $200, and all future payments will be distributed automatically starting October 1, 2026, with potential supplemental $149 payments by April 2027. Amazon has already issued more than $845 million in redress payments as of September 2026.