The first half of 2025 made one thing clear: enforcement on compliance issues isn’t slowing down.
PerformLine’s latest Marketing Compliance and Enforcement Actions 1H 2025 Review shows record activity, mounting fines, and an unmistakable shift toward state-led enforcement. Here are the themes that stood out from our report and what they mean for your organization’s compliance program.
Enforcement Surges
The numbers from the first 6 months of 2025 tell the story:
- 204 finalized enforcement actions
- $2.5 billion in fines
- 78% brought by state regulators
- 13% brought from private litigation
That’s nearly three times the activity and four times the penalties of 2H 2024.
Takeaway: State regulators are moving aggressively. Companies that aren’t monitoring state-level guidance are taking on significant risk. Join the COMPLY webinar on 8/27 to get the knowledge you need to stay ahead of regulatory trends.
Risk Areas: Familiar Issues, Higher Stakes
The violations aren’t new, but the consequences are intensifying. Key actions in 1H 2025 included:
- Deceptive marketing – A $165M case against a major insurer for misleading consumers into unnecessary coverage
- Discrimination – A $13.5M case for a bank engaged in discriminatory mortgage redlining practices
- Usurious or hidden-interest loans – A $77M case against short-term business lenders who charged illegally high rates and failed to disclose fees
- Hidden Junk Fees –$3M against a car dealer who deceptively advertised low prices and adding undisclosed fees at signing
Takeaway: This is the time to reinforce internal processes and get ahead of expectations.
Third-Party Marketing Under the Microscope
The FTC’s $50M action over undisclosed influencer deals signals a clear message: third-party marketing is your responsibility.
Takeaway: Whether it’s a social post, a video, or a brand collab, organizations must monitor all partner content for proper disclosures and compliance.
Federal Activity: Narrower Focus, High Stakes
Some companies may feel federal scrutiny easing, but the reality is more nuanced:
- OCC: Dropping “reputation risk” reviews, but emphasizing operational and compliance integrity
- FINRA: Tightening oversight on influencer and partner marketing
- CFPB: New guidance zeroes in on fraud and military protections while scaling back exams with a focus narrowed to banks and credit unions
Takeaway: Fewer touchpoints, but sharper consequences. Internal processes should be reinforced now.
Top 5 Compliance Issues We Flagged
From monitoring hundreds of thousands of assets, PerformLine identified the most common violations:
- Missing or incorrect disclosures
- Offer inflation and exaggerated claims
- Misleading credit terms
- Inappropriate use of “payday”
- Incentivization that obscures critical information
Takeaway: Each is preventable, but manual review to find them all isn’t scalable.
Compliance as a Competitive Edge
Leaders in 1H 2025 aren’t treating compliance as a checkbox. They’re using it to strengthen growth:
- Fintechs are securing better partnerships by embedding compliance from the start
- Banks are creating AI oversight committees to set higher standards for partners
- Compliance-first companies are launching faster with fewer delays
Takeaway: The pattern is clear: compliance done right accelerates—not slows—business.
PerformLine Makes Your Compliance Program Future Proof
With enforcement up and federal priorities shifting, manual processes can’t keep pace. PerformLine’s AI-powered platform empowers your team with automation to:
- Discover risks across every channel, including affiliates, partners, and influencers
- Monitor continuously across web, social, email, calls, and documents
- Act through remediations, and reporting, for any audit situation
Takeaway: Compliance is evolving. With the right technology, like PerformLine, your oversight will evolve with it.
