Affiliate marketers are not a separate protected class — they can be sued personally for the claims they make. The FTC has now collected on that exposure.
1. The claim they sold
The named defendants were top affiliate promoters for MOBE (“My Online Business Education”), an online business-coaching and “investment opportunity” scheme that the FTC alleges took in more than $125 million from thousands of consumers and ultimately caused more than $300 million in consumer losses. Affiliate ads used hooks including “How A Baby-Faced 22-Year-Old College Dropout Just Crossed $1 Million,” “This 14 Year Old Legally 'Clones' an Ecommerce Giant,” and claims that “even people in their 80's are making money by following 21 simple steps.” The defendants ran their own branded subprograms — “Dot-Com Lifestyle,” “Entrepreneurs Club,” “Rookie Profit System,” and others — to recruit into MOBE, taking a commission on every sale.
After MOBE was shut down by court order in 2018, Giannulis and Williams allegedly started My Ecom Club, a new deceptive coaching scheme using shell companies and “straw owners” to process payments — conduct the FTC calls credit card laundering — and reportedly took in roughly $8 million through My Ecom Club (per the FTC complaint).
2. The record
The FTC sued MOBE and its principal operators in June 2018 (FTC press release, June 2018) and obtained a court order halting the scheme and freezing assets. In March 2020, the FTC announced affiliate settlements:
- Giannulis, Williams, and their companies: $31.6 million judgment, suspended upon payment of $760,000 and turnover of personal items; permanent ban on selling business coaching or money-making methods.
- Gar Leong Chow: $3.35 million judgment, paid in full.
- Scott Zuckman: $1.8 million judgment, $406,150 paid, remainder suspended.
- Steven Bransfield: $4.7 million judgment, suspended due to inability to pay; Bransfield filed Chapter 11 in August 2019.
Each settlement permanently bans the defendant from selling or marketing any business-coaching program or money-making method, and the suspended portions become immediately payable if the defendants misrepresent their financial condition.
The MOBE founder, Matthew Lloyd McPhee (an Australian citizen based in Malaysia), separately settled FTC charges in February 2020, agreeing to surrender more than $16 million from his personal and company accounts (FTC press release, Feb. 13, 2020). All of these resolutions are civil settlements, not criminal convictions.
3. What it means for a buyer
This file is the textbook example of the FTC's “affiliates are liable” position. Affiliate marketers are not a separate protected class — they can be sued personally for the claims they make. The lesson for a buyer is that the person pitching the program carries personal legal exposure when the pitch is a lie. That exposure does not make the next affiliate honest, but it raises the cost of being dishonest, and the FTC has now collected on that exposure.
4. Current standing
Giannulis and Williams are under permanent injunctive bans on selling business coaching. The FTC press release on MOBE affiliate settlements dated March 2020 governs their conduct going forward.