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FTC disclosure (US)

Definition — In the United States, FTC truth-in-advertising rules and the Endorsement Guides apply to influencer marketing whether the influencer is human or synthetic: material connections must be disclosed, and AI personas must not pose as real customers.

There is no dedicated 'AI influencer law' in the US — and that is the point: the existing rules already apply. The FTC Act prohibits deceptive advertising generally, and the Endorsement Guides require that material connections between a brand and an endorser be disclosed clearly and conspicuously. A synthetic spokesperson promoting a product is advertising, and the same standards attach.

The sharpest edge for AI personas is testimonials. The FTC has moved directly against fake reviews and testimonials, including AI-generated ones: a synthetic persona presented as a real customer recounting a genuine experience is a fabricated testimonial, not a creative choice. An AI presenter can demonstrate, explain and pitch — it cannot claim a lived experience it never had.

Practically: disclose sponsorship the way the guides require (clear, conspicuous, near the claim, not buried in a hashtag pile), be transparent that the persona is synthetic, and keep claims about the product truthful and substantiated as with any ad. The disclosure legal guide covers the US and EU regimes side by side. This is general information, not legal advice.

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