The FTC is reading review campaigns. Yours included.
If your agency sends review requests for clients — SMS, email, QR — you're now running a regulated activity across every one of them. One non-compliant template deployed to fifty clients is fifty times the exposure. We audit what you're running, fix what's risky, and hand you the evidence file that proves you're clean.
This stopped being theoretical in December.
The FTC's Consumer Review Rule took effect October 2024. On December 22, 2025, the first warning letters went out. Google has banned review gating for years and suspends profiles for it. The era of "everyone does it" is over.
Maximum civil penalty per violation under the rule — per fake, gated, or improperly incentivized review practice.
Companies formally warned in the FTC's first enforcement wave, December 22, 2025. Law firms uniformly read it as "more coming."
Agencies multiply exposure: every client campaign you template is a place the same violation repeats.
Seven things we scan in every campaign.
SMS & email review requests
Every template, every sequence, every client — the full solicitation surface.
Review gating
Sentiment-filtered routing — happy customers to Google, unhappy to a form. Banned by Google; suppression risk under the FTC rule.
Prohibited incentives
Discounts, entries, freebies tied to reviews — including the "we didn't say positive" varieties that still fail.
Pressure & selective solicitation
Who gets asked, when, how often, and how hard — the patterns that read as manufactured consensus.
Platform-specific language
Google, Yelp and Healthgrades don't share a rulebook. Your templates have to pass each one they target.
Versioning & approvals
Who approved what, when — the workflow gap that turns one person's shortcut into agency-wide liability.
Client-ready evidence
Everything above, documented — so "show me we're compliant" has a one-click answer.
You get a file, not a lecture.
- Findings report — every violation pattern found, with the exact rule or platform-policy text it trips, ranked by exposure.
- Fixed templates — your campaigns rewritten to the nearest compliant variant (two-step feedback flows that still get you reviews, legally).
- The evidence file — versioned, client-ready proof of what runs and who approved it. Show it to a worried client, an insurer, or a regulator.
- "Review-safe" attestation page — a sales asset for your agency, not just a compliance cost.
Reputation Monster provides compliance tooling, detections and rule citations — not legal advice. Findings reference the FTC Rule on the Use of Consumer Reviews and Testimonials (16 CFR Part 465) and platform policies as of their stated review dates. For legal opinions, we refer you to independent advertising counsel (we partner with several).