> I seriously doubt that, unless otherwise stated, the FTC would do anything other than appropriate the funds for itself. The money goes to the Treasury. Congr

> I seriously doubt that, unless otherwise stated, the FTC would do anything other than appropriate the funds for itself. The money goes to the Treasury. Congress holds the purse strings. FTC fines are not designed to make victims whole; fines are inherently punitive. In our current system, restitution and civil damages fill that role; i.e., victims who want to be made whole should sue Mr. Brar individually, sue him as a class, and/or find a prosecutor who will go after criminal charges with restitution and make sure they're included as victims. The good news for victims is that the FTC settlement generally makes civil suits easier for victims to win. The settlement significantly increases the probability of success and significantly decreasing the cost of each individual victim's lawsuit. In particularly egregious cases, FTC settlements will require an explicit admission of guilt. Those admissions make victims' cases even easier to win (the victim only has to prove that they were defrauded; the question of whether the interaction was fraudulent is already settled). IMO the most appropriate structure for an FTC fine would be ${some multiple of the money you made scamming people, AFTER paying back all victims who decide to file a civil suit}. I think the ordering is exactly the opposite, though, unless the civil suits include punitive damanges. We'd have to find a bankrupcy lawyer to be sure.