Using influencers. Take precautions
If your business uses influencers to promote its products, hoping that your influencers will comply with the FTC endorsement guidelines (see FTC link) is no longer an option.
At the beginning of March 2020, the FTC settled for $1 million with Teami, a detox tea company and other wellness products. Teami had a social media policy that was sent to its influencers. Teami however did not monitor its influencers to determine if they were in compliance with its social media policy, and the FTC found that the influencers were not in compliance with the social media policy and its endorsement guidelines. As part of the stipulated order, Teami must monitor its influencers for compliance with the guidelines (see Order at p12).
If your business uses influencers, you need to ramp up your compliance program.