Compliance · disclosure and brand safety

FTC-safe clipping,
handled end to end

FTC-safe clipping means running paid creator distribution the way US endorsement rules require, so every post discloses the paid relationship, every clip passes a brand-safety review, and reach comes from vetted real creators and verified views. Because the FTC holds the advertiser responsible, we build the whole programme around that.

General information, not legal advice. Confirm your obligations with counsel.
The exposure

The FTC holds the advertiser responsible

A paid clip counts as an endorsement, so when a creator is paid to post, that's a material connection the law says has to be disclosed, and the brand carries the liability rather than just the creator. Every clipping agency sells you the reach and stays quiet about that part.

Who is liable

Your company is responsible for what creators do on its behalf

The FTC's enforcement focus lands on advertisers and their agencies first, so a brand is exposed whenever it fails to train, monitor or make sure its creator network runs a real disclosure programme.

FTC Endorsement Guides, updated June 2023
Common mistake

A platform "paid partnership" label isn't enough on its own

The FTC says the responsibility to disclose clearly and conspicuously sits with the brand and the creator rather than the platform, so relying only on a built-in label creates real risk.

FTC Endorsement Guides FAQ
The rules

The rules that apply to paid clips

The current US rules a paid creator programme has to meet, and each one comes straight from the FTC.

DiscloseMaterial connections must be clear and conspicuous

A paid or incentivised relationship has to be disclosed up front in plain language on every post, and a buried #ad or a vague #ambassador can fail that test.

FTC Endorsement Guides, updated June 2023
Oct 2024The fake reviews and testimonials rule is in force

Effective 13 October 2024, it bans fake or AI-written reviews, undisclosed insider reviews, and any compensation tied to a particular sentiment.

FTC final rule, announced 14 Aug 2024
$51,744Maximum civil penalty per violation

The rule carries civil penalties of up to $51,744 per violation. How a violation is counted is not defined in the rule.

FTC final rule, per Davis Wright Tremaine
Real onlyBuying or selling fake followers or views is prohibited

The same rule bars fake engagement where the buyer knew or should have known it was fake. Reach has to be real, which is why we bill only verified views.

FTC final rule, 2024
How we handle it

How we keep your clips FTC-safe

Four things we build into every campaign so the programme is safe to put in front of your legal team.

Disclosure on every post

The paid relationship is disclosed clearly and up front in line with FTC guidance, rather than buried or left to a platform label.

Brand-safety review on every clip

Every clip is reviewed against your brief and your brand rules before it goes anywhere near a feed.

Vetted real creators

Clips come from real accounts with real audiences, not bots. See the creator network.

Verified views only

You pay for real, counted views. The 2024 rule bans fake ones, so our billing and the law agree. See verified views.

The honest limit: we build for FTC-safe disclosure and brand safety, but we don't provide legal advice and the advertiser stays responsible for its own compliance, so confirm your obligations with your counsel.

Questions, answered straight

FTC-safe clipping, and the questions buyers ask

The honest version, written for whoever's name goes on the compliance sign-off. Every answer stands on its own.

What is FTC-safe clipping?

Running a paid creator clipping programme the way US endorsement rules require, so every post discloses the paid relationship clearly, every clip passes a brand-safety review, and reach comes from vetted real creators and verified views rather than bought engagement.

Who is legally responsible if a clip is not disclosed?

The advertiser. The FTC says a brand is responsible for what creators do on its behalf and its enforcement focus lands on advertisers and their agencies first, which is exactly why choosing an agency that handles disclosure properly matters.

Is a platform "paid partnership" label enough on its own?

No. The FTC states the responsibility to disclose clearly and conspicuously sits with the brand and the creator rather than the platform, so a built-in label can be part of it but relying on it alone creates risk.

Are bought views a compliance problem, not just a quality one?

Yes. The FTC's 2024 rule prohibits buying or selling fake followers or views where the buyer knew or should have known they were fake. We bill only verified views, so the model stays on the right side of that.

How does Lumina handle disclosure and brand safety?

At the programme level, so the paid relationship is disclosed on every post, every clip is reviewed against your brief before it goes out, creators are vetted and real, and views are verified. We'll walk your team through the specifics on a call.

Is this page legal advice?

No. This is general information about US FTC rules rather than legal advice, and it doesn't create any attorney relationship. Your obligations depend on your situation, so confirm them with your own counsel.

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Distribution your legal team can approve

Get the reach of a creator network with disclosure and brand safety built in, and we'll walk your team through exactly how it works.