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

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