ClickBank Responds to being a haven for deceptive “Make Money Online” products

by Jeremy Schoemaker on August 29, 2011 · 42 comments

Last week I wrote about the lawsuit google settled for 500 million for allowing advertisers to use their platform to place ads that were  illegal.

In the post I alluded to the fact that perhaps this would apply to havens like Clickbank (I also linked exact listings in my post) where rediculas income claims and testimonials are being made.  And that was just on the service.

I just got notice that this morning Clickbank has responded with a New Vendor Guidelines which specifically address the “make money online” category.

1. Testimonials and Endorsements

All use of testimonials and endorsements must comply with Federal Trade Commission (FTC) guidelines. This means that vendors cannot use false and deceptive statements in their written promotions or their video promotions. All specific advertising claims about a product’s performance or quality must be capable of substantiation—that is they must be real examples based on actual experiences. A statement that not all consumers will get the same results is not enough to qualify a claim. Testimonials and endorsements can’t be used to make a claim that the advertiser itself cannot substantiate.

Connections between an endorser and the vendor that are unclear or unexpected to a customer also must be disclosed, whether they have to do with a financial arrangement for a favorable endorsement, a position with the vendor, or stock ownership. Expert endorsements must be based on appropriate tests or evaluations performed by people that have mastered the subject matter. This means vendors cannot have actors (paid or unpaid) pretending to be someone they are not as part of a product endorsement. Also, affiliates cannot pose as neutral third parties evaluating two products so they make a commission on selling one of them.


Vendors must submit a script prior to shooting the video. Videos will not be accepted without a script pre-review.

We Will NOT Allow:

  • Videos that portray or reference a fictionalized individual or life story, where a vendor makes false claims as part of the product pitch.
  • Videos that portray or reference the vendor him or herself, where the vendor makes false claims about his earnings and experience as part of the product pitch.
  • Videos which will not allow viewers to exit or pause.
  • Expert endorsements without substantiation (for example, an endorsement from a doctor must have proof that the doctor has performed tests or evaluations performed and has mastered the subject matter being described in the pitch).

We Will Allow:

  • Videos and testimonials containing actors who portray consumers and describe their success using the product as long as the customer experience on the video accurately describes the performance of a “bona fide” customer and is associated with a disclaimer appearing with the actor making such a disclosure (ex: “Actor Portraying Real Purchaser”). Language may state “up to” a certain amount (so if some customers make $1000 and some make $500, you can use “up to $1000”), but should be based on a real customer who has an experience that is typical.
  • Videos and testimonials containing actors telling the vendor’s actual experience/story (either 1st or 3rd person). Must use a disclaimer that the person in the video is an actor representing the vendor’s actual experience.
  • Videos and testimonials containing a spokesperson describing the product’s actual attributes (must use a disclaimer).
  • Videos and testimonials containing an actual customer telling their actual story (does not require a disclaimer, but vendor must have signed documentation from the customer on hand in the event a regulatory agency would want proof that the story is a customer’s actual experience).
  • Videos and testimonials containing the actual vendor telling his/her actual story (does not require a disclaimer).
  • Again, any claims contained in the video must be able to be substantiated. ClickBank does not have to have the proof in hand, but the vendor must understand that if the FTC, private litigant or other agency asks for it, the vendor must have proof to back up any claim made in the vendor’s video.

2. False Scarcity

We Will NOT Allow:

False scarcity messaging when there is no actual scarcity of the product (for example, “Only 300 copies” when there are unlimited copies, tickers running down the amount of time there is to purchase, and listing that this is a one-time opportunity TODAY only). Bolded words for the “one-time opportunity TODAY only” are the key differences to what is accepted below.
We Will Allow:

  • Messaging that states that the offer is available for the next “xx” amount of time (such as, “If you order in the next ten minutes, you will get …” or “Order today for this amazing opportunity”), as long as there is no messaging that states that the offer is ONLY available for that short time, or that it is a one-time opportunity or chance to purchase when there will be other opportunities available.
  • Scarcity messaging used when there are actual limitations to the quantity or time that is communicated to ClickBank during the Product Approval Process. ClickBank will then monitor sales to ensure the sales are halted when the maximum number of limited products has been met or when the amount of time has expired. The offer can then be “reopened” again after 7 days.

3. Accurate Pricing

We Will NOT Allow:

Sale pricing that suggests that a product previously sold at a higher price (when it really didn’t) but is now on sale for a lower price for a limited time.

We Will Allow:

Real and genuine discounts from the normal price. Thus, if a vendor sold at $99 for a reasonable amount of time, it can drop the price to $79 and say, “$20 off!” The vendor cannot invent the $99 price, just to claim $79 is a sale price when it has always been sold for $79.

4. Upsells / One-Time Offers / Downsells


  • Initial product sold must be a standalone product of value. Any upsells or downsells must be enhancements to the initial product and must not be required to make the initial product work.
  • Decline links (“No Thank You” links) must be displayed clearly and conspicuously on the page:
  • Minimum of size 12 font,
  • Font in contrasting color to background color,
  • Decline link must be on the same page view as the “Accept” offer on a standard 1024 x 768 display (for example, no scrolling should be required if it is only to see the “No Thank You” link).

We Will NOT Allow:

More than 3 upsells (one time offers) and two exit offers for each sales flow.

5. Promotional Techniques

We Will NOT Allow:

  • Major brand/corporate logos on vendor Pitch Pages and Thank You Pages:
  • Except credit card logos next to payment links.
  • Unauthorized use of the ClickBank logo. For authorized usage, see our Trademark Use Guidelines article.
  • Exceptions can be made when vendor has documented authorization from major brand or corporation.
  • Qualifying criteria when no qualifiers are truly necessary to purchase the product. Qualifying criteria must have a demonstrated disqualifying criteria.
  • Statements that infer that the product is significantly easier to use than it really is (for example, “one push button to make money” or “three simple words will provide you income”). ClickBank requires that pitches make reasonable attempts to reflect the actual effort required to achieve typical results. It is generally unreasonable to assume that someone with little or no experience in Internet marketing can achieve a 6-figure income with an hour or less of effort per day. It is more reasonable to assume that with attention, effort, and spare time, the average person with little or no Internet marketing experience can achieve a supplemental income.
  • “As Seen On… ” statements without documentation showing that the product was seen on the stations, TV shows and/or magazines that are listed (not required for the product approval, but will be asked if they have it to provide if requested).

6. Pricing Requirements:

  • Prices must be presented clearly and conspicuously. For recurring billing products (including TRIALS + one rebill), the rebill schedule and pricing must be displayed clearly and conspicuously.
  • Minimum of size 12 font
  • Font in contrasting color to background color


full disclosure

About the author...

– who has written 2896 posts on

Jeremy "ShoeMoney" Schoemaker is the founder & CEO of the ShoeMoney Blog, Elite Retreat Internet Conference, & the PAR Program. In 2013 Jeremy released his #1 Amazon Best selling Autobiography titled "Nothing's Changed But My Change" - The ShoeMoney Story. Jeremy currently lives in Lincoln Nebraska with his wife and 2 daughters.

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1 SuperbadIM

It’s unfortunate that Clickbank has to create guidelines to tell people to BE TRUTHFUL. I guess when there is money to be made, it doesn’t matter if you’re building a sales page or a billion dollar investment portfolio – some people will always be willing to lie to get ahead.

At least Clickbank stepped up and took action. It will be interesting to see what effect it actually has. When you make rules, someone has to enforce them or they might as well not exist at all.

2 Miles Baker

I think these are good changes that go with the times and as the Internet matures so will companies that wish to survive. Also, this post seems a bit dated, ClickBank released this statement Aug. 2nd, almost a month ago.

3 Dave

The warrior forum is probably going completely ballistic now. Probably a few people not making their mortgage payment next month.

4 Courtney

So true! I remember seeing these emails come through, but they themselves were pretty inconspicuous…

Yes, the basic principles of their rules “seem” to be human decency; however, this is a lot of new guidelines that are required for continued service.

I don’t think consumers should be screwed, but then again I don’t want anyone to lose their way of life because they couldn’t change all of their products “pitching” techniques in 1 week.

5 Hafiz Dhanani

This is long overdue. The amount of low quality products on Clickbank in the biz opp space with extremely deceptive salespages is huge.

The products are so different from what the sales page suggests – a prime example is a product like “Commission Crusher”.

The problem is deceptive advertisers will still try and get around these rules, but hopefully the rules help increase the quality of products/truthfulness of sales pages.

6 Stephanie

I think the big challenge will be the affiliates, who also have to follow FTC rules. It’s much harder to catch affiliates making trouble because individual campaigns and sites aren’t approved before they start marketing.

7 Alon Cohen

There is no connection between your previous article and these new guidelines. Clickbank has been telling affiliates and vendors about these for over a month.

The timing between your article and these is just a coincidence.

8 Jeremy Schoemaker

Hmm well one of their employees emailed me saying that it was a response to my post… maybe that is a coincidence?

9 Alon Cohen

We’ve been getting notifications from them on that as far back as August 2. Stragne that the employee did not metion that to you.

10 Liam

That email was probably more of a “…since you just trashed us, you should probably be aware of these policy changes already in effect…” kind of thing.

Or do you really think they fear an obscure reference from a Shoemoney blog post more than the FTC?

11 Brennen

Yeah, myself and most vendors and affiliates have been told about these changes for quite awhile now. As a matter of fact, there were many launches in early August that were delayed or cancelled due to these changes.

12 AM

The vague FTC guidelines that were released a few weeks ago were a joke. But these rules from ClickBank seem perfectly reasonable to me. I guess that is the difference between people who are actually in the marketplace (ClickBank) and bureaucrats who have no idea what they are talking about (FTC).

13 Eddie

I think this is what exactly what the FTC wanted in the first place – for the AM industry to regulate itself rather than the government having to intervene.

14 Joe

The only annoying thing is the false scarcity they are trying to remove. That is the oldest sales trick in the book. Its used everywhere.

Anyway, you would have to be a complete idiot to believe any of the garbage being sold on clickbank or elsewhere. The losers in society are getting more and more protection. Where does it all end?

15 Tuan

They have a spelling/grammar error in their guideline?

“Except credit card logos next to payment links.”

Shouldn’t it be “accept” ?

16 Tegs

No, I think it’s supposed to be a part of the sentence above it.

We Will NOT Allow:

* Major brand/corporate logos on vendor Pitch Pages and Thank You Pages: Except credit card logos next to payment links.

17 fas

Clickbank was quick, that is why they are no1

18 Brian

What is going to happen when people cannot make money from deception or small print on the bottom.

19 2EC-O

Nice Post! Thanks for sharing.
I have been hearing that Click Bank will be closed soon and all the money will be gone too.
Is that true?

20 Lela

I have never bought from click bank because many people said that the majority of products were junk and scams. I think that even though they claim their not gong to allow a lot of that stuff, there is no way for them to check. Like when they say they will not allow fake testimonials. How could they stop it and prove that the person is fake.I think it is just a verbal for show but I don’t know if they are going to actually seek out the people who post products to click bank and make sure they are what they say they are.

21 Danny

About time!!!!!

Internet marketing needs a make over… People showing you how to sell money by creating more products on how to sell more money and building email lists on learning how to make more money online when they have actually never made a dime selling anything other that how to make money online selling products about making money online….

I’ve seen many of what used to be called Gurus, have already jumped out of the van wagon, and either expanded into other facets of technology & such or quit the internet completely…

I’m happy to see this happen, really needed in this industry

22 ben

About time too.

Do you know if ClickBank will be applying these rules retroactively to existing sales pages?
If so, how long do vendors have to comply? I just had a quick look and there are still lots of sales pages ignoring these; are these going to be enforced as rules or will they be unenforced guidelines?

23 Chris

About time this was done. There have been too many re-runs of the same type of empty of real real substance or outdated pretend products.

24 Justin

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25 Corey

I think these new guidelines Clickbank has put into place will ultimately help clean up the marketplace. If they aren’t effecting offers, they soon will. Clickbank will be auditing all their offers.

26 BlackBerry News Blog

Why does that surprise me….. NOT.
Let’s see if these are empty word shells or Clickbank is really cracking down on deceptive marketing.

27 Gabriel Smith

Fantastically useful thank you, It is my opinion your audience would probably want more content similar to this carry on the great work.

28 Johnny Jefferson

Particularly good many thanks, I do think your current subscribers would certainly want further reviews similar to this carry on the great hard work.

29 DIY Fashion Fanatic

I’m going to go with Danny, its about time! This will leave it open for the people who actually care and create quality products. I am all for it.

Great post BTW.

30 dslr deals

It was getting a little out of hand, something needed to be done. I heard a while back there was some (chances are not) ex-stripper that was able to run some one-click millionaire software and retire from shaking her money-maker. Give me a break.

31 Audiobook Online

I hate the ‘One Push Button’ or ‘Only 7 clicks to being a millionaire’ product promotions. They’re just so false and I unsubscribe from any list that sends them to me. I would never send those type of offers to my list. In fact, I’ve stopped promoting ‘Make money online’ stuff as so much of it is crap.

And as for the ‘As seen on Google or Yahoo or Youtube’ – what sort of reference is that, it means nothing. You don’t open Google and up pops a full screen as telling you that you’re just one click away from being a millionaire and even if it happened you’de have to be a retard to believe it.

It’s actually far more rewarding for me to promote something that I know is exactly what the person wants, and when they get it they aren’t going to be disappointed. Physical products work better for me. Just my 2 cents worth.

Chow chow,

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