This CLE program provides attorneys with a focused analysis of the legal and regulatory issues surrounding multi-level marketing (MLM) enterprises. As these models gain traction during periods of economic disruption, they have become frequent subjects of enforcement actions and private litigation, particularly where earnings representations and recruitment-driven compensation structures are at issue.

The course examines recent industry trends, including pandemic-era expansion through social media and digital platforms, followed by contraction, restructuring, and increased scrutiny. It also addresses the litigation and enforcement landscape arising from company failures, private equity rollups, and shifting regulatory priorities.

Participants will develop a working framework for evaluating MLM structures under federal and state law, with an emphasis on distinguishing lawful direct selling operations from prohibited pyramid schemes. Key topics include compensation plan analysis, deceptive marketing claims, distributor conduct, and the evidentiary and compliance challenges posed by online recruitment and emerging technologies.