What looks wrong
A row of ordinary five-star reviews on a big beauty retailer.
What’s actually going on
The FTC charged Sunday Riley Modern Skincare and its CEO with directing employees to post fake Sephora reviews from hidden accounts, then using a VPN after some reviews were removed. The 2020 final order banned the misrepresentation. It did not include a fine. Commissioners who dissented called that a slap on the wrist.
Online reviews are supposed to be other customers, not the people on the payroll. The FTC's 2019 complaint against Sunday Riley Modern Skincare said that, from 2015 to 2017, managers including the CEO posted product reviews on Sephora from fake accounts and told other employees to do the same.
The agency said that after Sephora took some of those reviews down, the company got a VPN account so the next batch would not share an office IP address. The complaint also described instructions to leave five stars and to 'dislike' negative reviews until they disappeared.
We are not naming rank-and-file staff or inventing customer identities. The public record is the company, the CEO as named in the FTC order, and the practice. In November 2020 the Commission approved a final consent order: no fake independence, disclose unexpected material connections. There was no money in the order. Two commissioners wrote that a no-fine, no-admission deal taught the wrong lesson.
The lesson for this magazine is simpler. A review cluster that all appears in a short window, all from new accounts, all with the same phrases, is a claim about a product — and a claim you can vote on.
Source: FTC final consent agreement, Sunday Riley Modern Skincare, 6 November 2020. We quote the public record. A settlement is not always an admission.