Consumers Affected
344,000,000
The FTC charged Marriott International and Starwood Hotels with failing to implement reasonable data security, leading to three data breaches affecting over 344 million customers. Under a proposed consent order, the companies must implement a comprehensive information security program, certify compliance annually for 20 years, and provide customers with ways to delete personal information and restore stolen loyalty points.
Marriott and Starwood must establish and maintain a comprehensive information security program with robust safeguards, undergo independent third-party assessments every two years, and certify compliance annually for 20 years. They must provide customers with a method to request deletion of personal information associated with their email or loyalty account, and review loyalty accounts upon request to restore stolen points. The companies are prohibited from misrepresenting their data security practices.
In-house legal teams should review vendor agreements (especially those involving data processing or IT services), customer privacy policies and terms of service, and employee data handling agreements. Specific clauses to scrutinize include data security obligations, breach notification timelines and procedures, data retention and deletion mechanisms, loyalty program terms regarding point security and restoration, and audit or certification requirements. Changes may be needed to incorporate specific security standards, mandate annual compliance certifications, establish clear processes for customer-initiated personal information deletion and loyalty point restoration, and strengthen third-party vendor oversight provisions.
Entity
Marriott International, Inc. and Starwood Hotels & Resorts Worldwide LLC
Also known as: Marriott
Industry
OtherOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2024/10/ftc-takes-action-against-marriott-starwood-over-multiple-data-breaches
1923022marriottacco
https://www.ftc.gov/system/files/ftc_gov/pdf/1923022marriottacco.pdf
1923022marriottcomplaint
https://www.ftc.gov/system/files/ftc_gov/pdf/1923022marriottcomplaint.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC"
"The FTC alleged that security failures by Marriott and Starwood resulted in at least three separate data breaches wherein malicious actors obtained the passport information, payment card numbers, loyalty numbers, dates of birth, email addresses and/or personal information from hundreds of millions of consumers"
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.
$225.0M
The FTC and the state of Washington filed a joint complaint and proposed stipulated order requiring Amway Corp. and two affiliates—World Wide Group, L.L.C. (WWG) and Leadership Team Development Inc. (LTD)—to pay a $225 million judgment, the largest monetary recovery ever obtained from an MLM in an FTC action, over allegations that they used deceptive earnings claims and unfair tactics to recruit Independent Business Owners. The complaint alleges the companies falsely promised substantial income and recruitment success, pressured IBOs to buy products they could not resell, and instructed IBOs to falsely report sales. Nearly all of the judgment will be used as redress for IBOs who lost money, and the proposed order imposes structural reforms including a 70% resale requirement, independent audits of sales records, and a ban on approved providers charging new IBOs for first-year training.
$100.0M
FleetCor Technologies Inc. (now Corpay Inc.) and its CEO Ronald Clarke agreed to pay $100 million to settle an FTC administrative action alleging the company charged small business customers hidden and unauthorized fees for fuel cards and misrepresented gas savings, fraud-control features, and fees. A federal district court granted the FTC summary judgment on all counts in 2023, and a federal appeals court upheld that judgment and the permanent injunction in 2026. The settlement funds will be used to provide redress to harmed business customers.
FTC staff published FAQs on price transparency to help the automobile industry comply with the FTC Act, reiterating that an advertised vehicle price must be the actual price any consumer can pay, excluding only government-required charges. The guidance follows warning letters the FTC sent to 97 auto dealership groups earlier in 2026 and signals continued litigation against dealers that advertise one price but charge more through undisclosed fees. No specific entity was charged and no penalty was imposed.