The claim
A number in a recruiting presentation is not a fraud by construction, and it is worth saying that before anything else.
Businesses publish earnings scenarios. A franchise disclosure document does it. Showing someone what the good outcome looks like is ordinary, and a prospect who wants a number before committing is asking the right question. The issue is never that a figure was shown. It is what the figure is made of, and how many people reach it.
Here is the figure, as the complaint describes it. Paragraph 17, page 10:
In recruiting and training presentations, WWG and LTD tell prospects and IBOs to recruit 6 to 12 IBOs themselves and to help those new IBOs to recruit as well. According to these standardized presentations, which Amway approves, IBOs who build a team of 25 to 48 IBOs will have “earnings” of about $40,000 a year. In WWG’s standard presentation, less than $1,000 of that sum is derived from retail margin from selling products to customers. The bulk of the remainder … comes from points generated by downline recruits. In other words, in WWG’s own demonstration of how to be a successful IBO, 96 percent of the IBO’s revenue comes from recruits.
The clause elided in the middle of that passage puts the remainder at more than $38,000. So on the complaint’s account, WWG’s own standard presentation builds a $40,000 year out of less than $1,000 of product sold to customers and more than $38,000 of points generated by people the IBO recruited.
The complaint also describes a ladder underneath that figure. Paragraph 130, page 43, says WWG presentations begin with an IBO whose personal purchases and online sales total 150 Point Value a month, which the complaint puts at about $500, and that “an IBO who has this blueprint for a year with no recruits will make $522.” Paragraph 131 describes the second rung, an IBO who recruits six people who copy the same blueprint, generating a retail margin of about $30 a month and what WWG’s slides call “Total Annual Earnings” of more than $3,900. The third rung is the one that reaches $40,000, and it takes 48 downlines.
Read the ladder as a document rather than as a pitch and it says something very specific. Every rung is bought with recruits, and the retail line barely moves between them.
Where these quotes come from, exactly. They are the regulators’ quotation of what named Approved Provider leaders said in recruiting and training sessions, as recounted inside the complaint. They are not taken from amway.com. This file did not obtain them from Amway’s own marketing and does not claim to have checked Amway’s current website copy against them. Paragraph 13, page 9, gives two of them directly: in a March 2023 online training a WWG leader, Maiko Tuitupou, told IBOs that if they developed a “consistent work habit … it’s not a matter of if, it’s a matter of when” they will achieve the levels associated with mid-five figure annual bonuses; and in a January 2025 training in Kansas City, an LTD leader said of a young IBO, “This works. This is a man who just followed the recipe of” recruiting and generating product volume “for a couple years.”
The evidence
Everything in this section is an allegation in the complaint of 17 September 2026 and is written as one. Where the complaint describes Amway’s participation and bonus data, that is the FTC’s and Washington’s characterisation of Amway’s own records. It is not an admission, and no court has tested it.
The median. Paragraph 14, page 9:
In fact, most IBOs come nowhere near the dollar figures that appear in the Approved Providers’ slide presentations for prospects, which are approved by Amway. In 2023, for instance, median total bonuses (before expenses) for IBOs were only $139, and IBOs often spend more on training they buy from Approved Providers than they receive in bonuses.
Paragraph 77, page 26, gives the same figure with its neighbour: “in 2022, median total bonuses received by IBOs were $145, and in 2023 that figure was $139.”
Exhibit A. The presentation ladder, against the median the complaint reports
How many reach it. Paragraph 75, pages 25 to 26: “In 2023, fewer than 1,600 IBOs out of 241,000 IBOs, or approximately 0.7% of IBOs, obtained annual bonuses of $40,000 or more.” Paragraph 76, page 26: “In 2023, for example, fewer than 350 IBOs or about 0.1 percent of IBOs in Amway received bonuses of $100,000 or more from Amway out of over 241,000 IBOs.” The same paragraph adds that those IBOs, or a prior generation of ownership from whom they inherited their IBO, had joined Amway an average of 28 years earlier, with a median of over 26 years, and that 142 IBOs across WWG and LTD combined, about 0.2 percent of the IBOs in those groups, received over $100,000.
Exhibit B. Share of IBOs reaching each figure in 2023, on the complaint's own account
What the figures are gross of. Paragraph 134, page 45, alleges that WWG’s recruiting presentation slides refer to bonuses and other potential revenue of $522 or about $3,900 as “Total Annual Earnings” for IBOs. Paragraph 135, on the same page, alleges that paying for WWG’s membership, audios, messaging app and major event tickets alone for a single person costs over $2,100 a year, that annual costs in LTD range from over $1,600 to over $3,600, and that in 2022 WWG itself estimated the annual cost for one person to be in WWG at between $3,500 and $5,500, and for a couple at between $4,000 and $6,000. If both allegations hold, the second rung of the ladder and the cost of standing on it are the same order of number.
What the products cost. Paragraph 36, page 15, alleges that until recently Amway priced a case of water containing 24 bottles of 16.9 fluid ounces at $52, and that IBOs buying from Amway received a 10 percent discount off the suggested retail price. Paragraph 15, page 9, gives the IBO side of the same item: a case of water “costs them more than $45.” The two numbers are not in conflict. One is the price a customer sees, one is the price an IBO pays, and the complaint prints both.
How rare the top is. Paragraph 73, page 25, alleges that between January 2020 and March 2024 more than 750,000 IBOs in the United States bought or sold an Amway product, and that only 2.2 percent of them ever reached the level of Platinum or higher, with one-tenth of 1 percent ever reaching Diamond or higher. Paragraph 74 adds that the 15 IBOs who made Diamond for the first time in 2020 and 2021 took a median of over 21 years to get there, and that eight of the 15 no longer qualified by March 2024.
What the evidence supports and does not
Supported. That a complaint and a stipulated order exist, that both were filed on 17 September 2026 in the Western District of Washington under Case No. 2:26-cv-03474, and that they contain these specific allegations and these specific dollar figures. The docket stamps are on every page of both documents: “Case 2:26-cv-03474 Document 1 Filed 09/17/26 Page 1 of 83” and the same case with “Document 2-1” and “Page 1 of 42”.
Not supported, and not claimed here. That any of it is true. The stipulated order says so in terms, at Findings paragraph 3 on page 2: “Defendants neither admit nor deny any of the allegations in the Complaint, except as specifically stated in this Order. Only for purposes of this action, Defendants admit the facts necessary to establish jurisdiction.” That is the whole of what has been admitted. This post does not say that Amway, WWG or LTD deceived anyone. It says the FTC and Washington allege it.
The $225,000,000 is agreed, and it is not ordered. Section VIII of the stipulated order, pages 24 to 26, sets out four judgments: $154,700,000 against Amway Corp.; $39,780,000 against World Wide Group and Amway jointly and severally; $26,520,000 against Leadership Team Development and Amway jointly and severally; and $4,000,000 in favour of Washington State. Those four add to $225,000,000 exactly. Each of the first three records that the money is held in escrow by Kelley Drye & Warren LLP, which page 35 also lists as counsel for Amway Corp., an ordinary arrangement worth stating plainly rather than leaving to inference. And each of the first three attaches the same condition: “Such payment must be made within 7 days of entry of this Order”. The Washington payment is due no later than 30 days after entry. Entry has not happened. Page 32 carries the line “SO ORDERED this ___ day of _, 202” above an empty rule where a United States District Judge signs. The two gaps rendered here as underscores are blank rules in the filed PDF; the only characters actually printed in the year are “202” and the two blanks after it. The FTC’s own press release states the rule without being asked: “Stipulated final orders have the force of law when approved and signed by the District Court judge.” The FTC’s case page read “Case Status: Pending”, last updated 17 September 2026, when it was checked again on 18 September 2026.
Exhibit C. What the $225,000,000 is made of, and which part is not redress
The $4,000,000 is not part of the consumer pool. The order describes it as recovery “for costs and reasonable attorney’s fees incurred by Washington in pursuing this matter, for monitoring and potential enforcement of this Order, for future enforcement of RCW 19.86”. The redress language sits in a different subsection, covering money received by the Commission: those funds “may be deposited into a fund administered by the Commission or its designee to be used for nationwide consumer relief”. Two different destinations, and this file will not blend them.
Nothing has been paid. The FTC’s release says “Information on the FTC’s redress program for this case will be provided at a later date.” The Washington Attorney General’s release says “Thousands of Washingtonians may be eligible for compensation that the FTC will administer.” May be eligible, at a later date, is the current state of the record.
Amway’s position is on the record, and it is not a non-response. This file sought comment from nobody and says nothing about anyone’s silence. It does not have to here, because a named outlet obtained a statement. The Washington Examiner reported on 17 September 2026 that an Amway spokesperson said: “Amway rejects the agencies’ assertion that the company’s sales data is not accurate. In fact, Amway and the FTC have agreed to rely on our sales data to continue tracking and substantiating IBO customer sales.” That statement goes to the foundation of every figure in Exhibits A and B, and it belongs on the page next to them.
Not knowable from these documents. Which IBOs will receive anything, how much, or when. What any individual IBO earned or spent. Whether the district judge will enter this order as filed. These two documents describe a settlement between three companies and two governments. They do not yet describe an outcome for a single person.
Cause of death
Not the $40,000. The word “earnings.”
The reflex on seeing a five-figure income scenario is to argue about whether it is achievable. That argument is a trap, because it can always be answered with a true story about somebody who got there, and on the complaint’s own numbers such people exist: fewer than 1,600 of them in 2023, but not zero. Arguing about achievability concedes the frame.
The complaint points somewhere better. On its account, the $40,000 in WWG’s standard presentation is built from less than $1,000 of retail margin and more than $38,000 of points generated by downline recruits, which is 96 percent of the figure. If that is right, the presentation was never forecasting how much product a person would sell. It was forecasting how many people that person would sign up, and how many people those people would sign up. Those are not the same forecast, and only one of them involves a customer.
That distinction is the whole autopsy, because it changes what the prospect is being asked to verify. A sales forecast can be checked against demand: is the product priced where people buy it, does anyone outside the room want it. The complaint alleges an answer to that too, at paragraph 36, where a case of water is priced at $52 in a category that Amway’s own former Vice President of Sales is quoted describing as “not a product with high retail appeal”. A recruiting forecast cannot be checked at all, because it is a claim about the future decisions of people the prospect has not met yet. Put it in a table with dollar signs and it looks like the first kind of claim while behaving like the second.
Then there is the second number in this story, and it dies of something different. $225,000,000 is real in the sense that three companies have stipulated to it and the money is sitting in an escrow account. It is not real in the sense that anyone owes it today. The order’s own payment clauses run from “entry of this Order,” and the FTC’s own note says stipulated final orders have the force of law when approved and signed by the District Court judge. Between an agreement and an obligation sits one signature that has not been written, and between an obligation and a payment sits a redress program whose details, by the agency’s own statement, come later.
Agreed is not ordered. Ordered is not paid. This file will keep those three words apart until a docket makes them the same.
What would change this verdict
- Entry of the stipulated order. A signature and a date on page 32 converts every figure in Exhibit C from agreed to ordered, and starts the seven-day and thirty-day payment clocks. That is the single event this entry is waiting for.
- Rejection or modification by the district judge. A court is not obliged to enter a settlement as filed. Any change to the terms changes this page.
- Money actually reaching IBOs. The FTC has said redress details come at a later date. When a program opens and funds move, ordered becomes paid, and this file will say so with the same care it is using to withhold the word now.
- The independent auditor. Section VII of the order requires an outside auditor with real-time access to Amway’s records, selected by agreement within thirty days of entry. Whatever that auditor produces would be the first account of Amway’s sales data from someone who is neither the company nor its regulator.
- A test of the underlying data. Amway has publicly disputed the agencies’ characterisation of its sales data, and because the defendants neither admit nor deny the allegations, nothing in this settlement resolves that dispute. If it is ever resolved, the $139 and the 0.7% get tested rather than quoted.
One thing that will not change it: an appeal. Findings paragraph 5 on page 2 records that all parties “waive all rights to appeal or otherwise challenge or contest the validity of this Order.” The only forward-looking penalty figure anywhere in the document is at Section XVI on page 32, where Washington may seek civil penalties of up to $125,000 per violation if a court later finds a material breach of the order. That is a number about the future, and it is the only one here that is.
Documents
| Document | Issuer | Date | Posture |
|---|---|---|---|
| Complaint for Permanent Injunction, Monetary Judgment, Civil Penalty Judgment, and Other Relief | Federal Trade Commission and State of Washington | Filed 09/17/26, W.D. Wash., 83 pages | Plaintiffs’ pleading. Untested, unadmitted, unadjudicated. |
| Stipulated Order for Permanent Injunction, Monetary Judgment, and Other Relief | Federal Trade Commission and State of Washington | Filed 09/17/26, same case, 42 pages | Proposed consent order. Signed by every party, not signed by the court. |
| FTC Takes Historic Action Against Multilevel Marketing Operator Amway for Unfair and Deceptive Business Practices | Federal Trade Commission | 17 September 2026 | Announcement of a filing. Conduct alleged throughout. Commission vote 2-0. |
| Amway, FTC v. case page | Federal Trade Commission | Last updated 17 September 2026 | Case-tracking page. “Case Status: Pending”, re-checked 18 September 2026. |
| WA, FTC reach $225M settlement with Amway for unfair and deceptive business practices | Washington State Attorney General | 17 September 2026 | Independent corroborating release, same figures. Source here for the eligibility line only. |
| FTC coverage of the $225 million Amway settlement | Washington Examiner | 17 September 2026 | Press report. Sole source here for Amway’s on-the-record statement. |
Both court documents were downloaded from ftc.gov and read directly on 18 September 2026, and every quotation above was matched against the text as served on that date. The one number in this post that is not quoted from a document is the sum of the four judgments in Section VIII, which is arithmetic: $154,700,000 plus $39,780,000 plus $26,520,000 plus $4,000,000 is $225,000,000.
The previous entry in this docket, AUTOPSY #017, held a complaint at arm’s length because a pleading is one side’s account. This one is held at arm’s length twice over. The pleading is still one side’s account, and the settlement beside it is an agreement in which the other side expressly admitted nothing except that the court has jurisdiction. The largest sum the FTC says it has ever obtained from a multilevel marketing company sits behind a blank line, and until someone fills that line in, blank is what this page will say.