Or will it be like shooting fish in a barrel? With hundreds of ISO s offering to board any type of merchant, knowing that their products have little or no value and by nature must be sold deceptively, the FTC can throw a dart in the dark and likely hit a culpable mark.
It won’t be difficult for them to view consumer complaints, select the most egregious merchant behavior, file a TRO and complaint against the merchant, and include the ISO as a defendant.
And is the ISO’s acquirer in the clear? I don’t think so.