It's not just that Fred was signed up using illegal tactics. The culpability comes from the fact that these US companies are paying the scammers to do this. The

It's not just that Fred was signed up using illegal tactics. The culpability comes from the fact that these US companies are paying the scammers to do this. The number or complexity of intermediaries is morally immaterial. That's why industries where these kinds of scams happen get special regulations. Advertising for some reason has just escaped oversight for now.