Privacy & Information Security Law Blog

On March 27, 2025, the Federal Trade Commission announced that it had reached a $17 million settlement with Cleo AI, Inc. (“Cleo AI”), an online cash advance company, over alleged deceptive representations regarding the company’s services and subscription cancellation process. 

The FTC’s complaint alleged that Cleo AI made deceptive representations about the amount of money consumers could receive by using the company’s services and about how fast the advanced money would become available. 

The FTC also alleged that Cleo AI made it difficult for consumers to cancel their subscriptions.  The FTC’s allegations built on reports from consumers claiming that the company continued to charge for monthly fees after the consumers’ repeated requests to cancel. The FTC also alleged that Cleo AI represented to consumers that the company could not cancel subscriptions until a consumer paid all outstanding cash advances on their account. 

The proposed settlement order would prohibit Cleo AI from misleading consumers about the material terms of its cash advances. In addition, Cleo AI agreed to clearly and conspicuously disclose the terms of its subscription services, to obtain consumers’ express and informed consent before charging them for a subscription, and to provide a simple and straightforward way for consumers to cancel their subscription.

The FTC says that it will use the $17 million payment from Cleo AI to provide refunds to consumers harmed by the company’s practices.