# Affiliate and paid-promotion fraud
Source: https://paymentsandrisk.com/docs/fraud/types/affiliate-fraud

Last updated 27 October 2026.

TL;DR

-   **Affiliate fraud** = a partner you pay for sales, leads or views fakes them, or claims sales it didn't cause
-   It's different from [promo abuse](https://paymentsandrisk.com/docs/fraud/types/promo-abuse/), where customers game your offers
-   Many attribution fights aren't fraud. They're gaps in your terms, so write the rules before you pay
-   Approve commission after your refund wait, and compare each partner's refunds and disputes with the rest
-   In the US, you can be responsible for what your affiliates claim about your product. [FTC](https://www.ftc.gov/business-guidance/resources/ftcs-endorsement-guides-what-people-are-asking)

You pay partners for results: a sale, a sign-up, a lead or a view. Some partners fake the result, or take credit for one they didn't cause. You pay commission on activity that wasn't real. Refunds or chargebacks can follow.

Where to go next

-   [One partner's orders keep getting refunded or disputed](https://paymentsandrisk.com/docs/fraud/types/affiliate-fraud/#signals)
-   [What should my affiliate terms say?](https://paymentsandrisk.com/docs/fraud/types/affiliate-fraud/#controls)
-   [Am I responsible for what affiliates post?](https://paymentsandrisk.com/docs/fraud/types/affiliate-fraud/#their-claims)

## Fraud, or a terms dispute?

Some practices deceive you wherever they happen. Others are a problem only if your terms ban them. Sort the case first, because the response differs.

| Practice | What happens | Usually treated as |
| --- | --- | --- |
| Cookie stuffing or forced clicks | The partner's tracking is set on a visitor who never chose its link. It's credited for sales it didn't cause | Deception. [A US prosecution](https://www.justice.gov/usao-sdal/pr/cookie-stuffing-internet-fraud-schemer-pleads-guilty-0) |
| Fake leads or sign-ups | Bots, paid workers or stolen details fill in forms to earn per-lead pay | Deception |
| Orders on stolen cards | Orders are placed on stolen cards to earn commission. The chargebacks land on you | Deception, and [third-party fraud](https://paymentsandrisk.com/docs/fraud/types/third-party/) |
| Bot or bought views | A pay-per-view claim includes views from bots or fake accounts | Deception |
| Bidding on your brand name | The partner buys search ads on your name and earns commission on customers already looking for you | A terms question |
| Coupon sites and browser extensions | A code or extension takes the last click at checkout, replacing the partner who earned the sale | A terms question. If it sets tracking without the visitor acting, treat it like cookie stuffing |
| Incentivized traffic | Visitors get a reward for clicking or signing up | A terms question |

## Signs worth checking

None of these proves fraud. Each is a reason to pull that partner's orders and look. Compare a partner with others of similar size. Wait until it's got enough orders to judge.

-   Conversion far above your other partners
-   Clicks, sign-ups or views bunched into a few hours
-   Refunds or chargebacks on that partner's orders well above the rest
-   Credit that almost always lands on the last click before checkout
-   Leads that never answer, or that share phone numbers, addresses or devices
-   Views that jump with no matching comments, follows or sales

## Controls

Start at sign-up. A light identity check on each partner helps. See [when you need KYB](https://paymentsandrisk.com/docs/fraud/prevention/kyc-kyb/#when-you-need-kyb).

Then write the program terms before anyone earns:

1.  **Approve commission after your refund wait.** Pay on sales that are still standing. See [commission terms](https://paymentsandrisk.com/docs/operations/paying-affiliates-and-contractors/#commission-terms)
2.  **Say what's allowed.** Brand-name bidding, coupon sites, browser extensions and incentivized traffic: allowed or not, and on what terms
3.  **Ask how they'll send traffic.** Get the channels in writing at sign-up. Check them again when a partner's sales change
4.  **Start new partners small.** Cap commission until they've got a track record
5.  **Track refunds and disputes per partner.** That works only if [every sale records which partner drove it](https://paymentsandrisk.com/docs/payments/buying-payments/underwriting/#affiliate-marketing)
6.  **For pay per view, agree what counts.** A platform's view count alone can't show the views were real. Set eligibility rules, spot-check posts and cap pay per post

## Their claims are your problem

In the US, the FTC's Endorsement Guides say an advertiser can be liable for misleading claims made through its endorsers. That includes a paid relationship the endorser didn't disclose. You can be liable even when the endorser isn't. The Guides expect you to give endorsers guidance, monitor them and act when they get it wrong. Doing that isn't a safe harbor. [16 CFR 255.1(d)](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-255/section-255.1).

The FTC's answers for advertisers say affiliates should disclose the relationship clearly. The words "affiliate link" alone may not be understood. [FTC Endorsement Guides: What People Are Asking](https://www.ftc.gov/business-guidance/resources/ftcs-endorsement-guides-what-people-are-asking).

So give affiliates approved claims and a disclosure line. Search what they post, and get wrong claims corrected. Processors may check affiliate sites too: see [affiliate marketing in underwriting](https://paymentsandrisk.com/docs/payments/buying-payments/underwriting/#affiliate-marketing).

**Fake views and followers.** The FTC's rule on reviews and testimonials makes it unlawful to buy fake followers, views or likes you knew or should have known were fake, to materially misrepresent your influence or importance for a commercial purpose. Selling them is covered too. [16 CFR 465.8](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465/section-465.8). So don't buy them for your own accounts. Fake reviews are a related problem: see [fake review fraud](https://paymentsandrisk.com/docs/fraud/types/application-fraud/#fake-review-fraud). The FTC says hiring an influencer who happens to have fake followers isn't covered. [FTC rule Q&A](https://www.ftc.gov/business-guidance/resources/consumer-reviews-testimonials-rule-questions-answers). A partner who fakes views to get paid is a program problem first. Your terms and records decide what you can recover.

## You've found it. Now what?

1.  Save the orders, clicks, leads or view reports behind each payment
2.  Check what your terms allow: holding commission, reversing it, or ending the partnership
3.  Hold new approvals for that partner while you check, if your terms allow it
4.  Stolen cards involved? Follow [third-party fraud](https://paymentsandrisk.com/docs/fraud/types/third-party/) and tell your processor
5.  Keep every record together in case the partner or its network disputes your decision

Where This Breaks

The FTC material here is US guidance and rules. Other countries have their own advertising rules. Affiliate networks set their own terms too, and those can decide a dispute before your own terms do.

Test to Run

Export last quarter's sales by partner. For each partner with enough orders to judge, compare its refund and dispute rate with your other partners. Pull the orders behind any partner well above the rest.

## Next Steps

-   [Paying affiliates, creators and contractors](https://paymentsandrisk.com/docs/operations/paying-affiliates-and-contractors/): Collect tax forms and set commission terms
-   [Promo abuse](https://paymentsandrisk.com/docs/fraud/types/promo-abuse/): When customers game your offers
-   [Third-party fraud](https://paymentsandrisk.com/docs/fraud/types/third-party/): When orders come from stolen cards
-   [Underwriting](https://paymentsandrisk.com/docs/payments/buying-payments/underwriting/#affiliate-marketing): What processors check about your affiliates

## Sources

| Source | Supports | Opened |
| --- | --- | --- |
| [16 CFR 255.1(d)](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-255/section-255.1), eCFR | Advertiser liability for endorsements and undisclosed connections; guidance, monitoring and remedial action; not a safe harbor | 27 October 2026 |
| [FTC Endorsement Guides: What People Are Asking](https://www.ftc.gov/business-guidance/resources/ftcs-endorsement-guides-what-people-are-asking) | Affiliates should disclose clearly; "affiliate link" alone may not be understood; advertisers should monitor their networks | 27 October 2026 |
| [16 CFR 465.8](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465/section-465.8) and [465.1](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465/section-465.1), eCFR | Buying or selling fake indicators of social media influence; what counts as fake; views, followers and likes as indicators | 27 October 2026 |
| [US Attorney's Office, Southern District of Alabama: cookie-stuffing guilty plea](https://www.justice.gov/usao-sdal/pr/cookie-stuffing-internet-fraud-schemer-pleads-guilty-0), 24 June 2014 | Forced clicks earned commissions on sales the affiliate didn't generate; charged as conspiracy to commit wire fraud | 27 October 2026 |
| [FTC Consumer Reviews and Testimonials Rule: Questions and Answers](https://www.ftc.gov/business-guidance/resources/consumer-reviews-testimonials-rule-questions-answers) | Hiring an influencer who has fake followers isn't covered; the knew-or-should-have-known standard | 27 October 2026 |