One Year In, FTC's "Operation AI Comply" Continues Under New Administration, Signaling Enduring Enforcement Focus

Key Takeaways:

• What began last fall as a signature policy under the previous administration has demonstrated its staying power. The Federal Trade Commission (FTC) is actively continuing "Operation AI Comply," its targeted initiative against deceptive marketing claims involving artificial intelligence. The agency continues to bring actions against businesses across industries for "AI washing" and deceptive advertising.
• Companies using AI in their marketing must be able to substantiate every claim they make, both explicit and implicit. This ongoing enforcement signals significant legal and reputational risks for any company promoting AI-powered products or services. The FTC is scrutinizing claims about AI performance, earnings potential and authenticity—and violations can result in multimillion-dollar penalties, compliance orders and costly investigations.