FTC issues 2018 guidance on MLM pyramid schemes

New year, new guidance from the FTC on MLM pyramid schemes.Sort of…In a January 4th “offer of business guidance concerning multi-level marketing”, the FTC has attempted to clarify common questions and concerns related to MLM and pyramid schemes.For some reason the FTC inexplicably goes to great lengths not to mention “retail sales” in their guidance, but they do refer heavily to “ultimate users”.This is a bit confusing, as ultimate users” can refer both to affiliates and retail customers.The FTC’s 2018 guidance is rooted in the 1975 Koscot decision,which observed that such enterprises are “characterized by the payment by participants of money…