Thomas Cohn - Small Business Trends

Welcome to this interview of Thomas Cohn, a well-known consumer regulatory attorney, former Federal Trade Commission?(FTC) Regional Director, and 17 year FTC veteran. At Affiliate Management Days East 2012 (on Oct 9-10, 2012), Thomas will be speaking on FTC and State actions versus affiliates and merchants and how to comply with consumer laws to avoid regulatory scrutiny.

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Question: What are the major affiliate marketing threats that you have seen evolve over the past few years on the legislative front?

Thomas: ?There?s a big direct threat on the state level (sales tax legislation). ?On the federal level, there are only indirect threats such as the limited situations in the ?Rockefeller Bill? that became ROSCA.

Beyond legislation, there are new FTC regulations implementing legislation, like the MARS Rule (banning advance fees for mortgage assistance) and the Business Opportunity Rule (more stringent disclosure requirements, covering more types within definition).

But the threat even bigger than legislation or regulation, is simply the continual increase in enforcement actions by state AGs and the FTC against deceptive online marketing, and against the roles played in it by not just merchants, but also affiliates, networks, and others who allegedly play a role in helping to apply the deceptive practices against consumers.

Question: Can you give us an example of a case involving legal compliance?

Thomas: The actions that FTC has brought in the last 12 months have highlighted the FTC?s awareness of deceptive tactics in affiliate marketing, and its increasingly aggressive stance in going after them. ?Whether they involve merchants, affiliates, networks, or other third parties whom the FTC believes are ?assisting and facilitating? these tactics.

This includes FTC cases against merchants like Central Coast Nutraceuticals, Jesse Willms and LeanSpa. ?The ten FTC cases brought against individual affiliate marketers, and the two FTC cases against affiliate networks.

Other third parties may be vulnerable, too: lead generators, list brokers, payment processors and call centers have all been targeted by the FTC. ?There may be more investigations and/or actions against such third parties.

Question: What can affiliate managers merchants do to ensure? compliance with the laws and avoid regulatory scrutiny?

Thomas: Take a look at the enforcement actions cited above that have final orders requiring monitoring, and see how onerous these are to actually implement! ?Then realize that while these don?t apply to everyone, just to the named defendants, you should still consider them in your risk calculus.

Finally, come up with a robust monitoring program that you actually can and will follow, by checking out both merchants and their offers, and affiliates? published content, before doing business with them.

Then, after offers start running, periodically check up on at least those merchants and affiliates that are performing the best, to see just why they are the top performers. ?Are there any deceptive/false/unsubstantiated product claims, including testimonials/endorsements? ?Are there deceptive formats? ?Are there inadequate or missing negative option/free trial and/or continuity/rebill disclosures?

If so, either enforce modifications or terminate the relationship.

Question: What can the affiliate marketing industry do to ensure its growth, regardless of the emerging legislative challenges?

Thomas: Same as above. ?Make sure both merchants and affiliates stay as compliant as possible, or stop doing business with those who don?t. ?The best way to ensure growth is to stay on top of the content being published by reasonably monitoring merchants? and affiliates? advertising.

While online privacy is a perennial hot topic, affiliate marketers and affiliate networks may not be affected much by whatever behavioral targeting legislation is eventually passed. The more immediate privacy-related issue is data security. ?If you ?say what you do? with your consumer data, then you better ensure that you ?do what you say.?

Any major hacking attack or other data breach could quickly bring an FTC investigation and/or enforcement action.

Question: If you were to leave affiliate managers with just one piece of advice today, what would it be?

Thomas: Compliance monitoring.?It doesn?t have to be perfect, but has to be reasonable and consistently implemented.

The FTC doesn?t care about cloaking/masking or other difficulties that affiliate networks/managers face in monitoring affiliates. The FTC?s view is that, if network profits are based on traffic that converts, then the network must do better to ensure compliant affiliate content.

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Affiliate Management Days takes place October 9-10, 2012. More information about Affiliate Management Days being held in Ft Lauderdale, can be found here. Or follow the hashtag #AMDays on Twitter. There?s still time to register using code SBTAM150 to receive $150.00 off your pass.

Be sure to check out the rest of the?interview series from #AMDays.

About Geno Prussakov

Geno Prussakov is the Founder & Chair of Affiliate Management Days and the CEO & founder of AM Navigator LLC. As an award-winning affiliate marketing expert, he has contributed to the online marketing success of such top brands as Forbes, Nokia, Hallmark, Warner Music, Skype, Forex Club, and hundreds of small businesses.

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Source: http://smallbiztrends.com/2012/09/thomas-cohn-legislative-challenges-affiliate-marketing-amdays.html

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Prison Planet.com ? Chalk Writing The New Terrorism

Prisonplanet.com
Sept 25, 2012

Amy Larson readily admits writing ?9/11 Truth? and ?9/11 Truth Now? in chalk on the First Street sidewalk over Napa Creek.

?I just want people to think for themselves,? said Larson, 29. ?I believe we?ve lost a lot of civil liberties since the 9/11 attacks. I?m really concerned about that.

?This is political free speech,? added Larson, who says the investigation into the terrorist attacks in New York City and Washington, D.C. should be reopened.

Her chalk writing ? which occurred Sept. 11, the 11th anniversary of the terrorist attacks ? got Larson arrested on suspicion of vandalism.

Print this page.

Source: http://www.prisonplanet.com/chalk-writing-the-new-terrorism.html

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Source: http://www.sodipodi.org/home-improving-in-phoenix-get-your-project-off-to-an-excellent-start-with-planning.html

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U.S. clears path for more sanctions on Iran oil deals

WASHINGTON (Reuters) - The U.S. government officially linked Iran's state oil company to the country's Islamic Revolutionary Guard Corps on Monday, a determination that enables Washington to apply new sanctions on foreign banks dealing with the company.

The Treasury Department determined that the National Iranian Oil Company, one of the world's largest oil exporters, is "an agent or affiliate" of the IRGC, which the United States has long put under sanctions for terrorism and human rights abuses.

The U.S. Congress directed Treasury to determine whether Iran's oil and tanker companies were linked to the IRGC as part of a new package of sanctions signed into law in August.

Adam Szubin, the head of Treasury's Office of Foreign Assets Control, told Congress in a letter that the IRGC's influence has grown in the oil company, a petroleum and natural gas producer based in Tehran, and throughout Iran's energy sector.

Iran's elite guard force has recently been coordinating a campaign to sell Iranian oil in an effort to evade Western sanctions, specifically the EU's Iranian oil embargo that went into force in July, the Treasury Department said.

But Szubin said there was not enough information at this time to conclude that the National Iranian Tanker Company was also linked to the IRGC.

Senator Robert Menendez, a Democrat who helped craft the sanctions law, urged the Obama administration to continue investigating whether Iran's elite guards are linked to the oil tanker company.

U.S. backers of sanctions applauded the ruling, part of Washington's wider net of oil-related sanctions aimed at choking funding to Iran's nuclear program. The West says Iran is developing weapons, but Tehran says its nuclear program is purely for civilian purposes.

"Oil transactions with NIOC directly support the IRGC's role in Iran's nuclear-weapons program and its support for terrorism," Representative Howard Berman, the top Democrat on the House Foreign Affairs Committee, said in a statement.

NOT WORTH THE DOWNSIDE

While U.S. companies already are prohibited from buying Iranian oil, the new determination means the United States can impose further sanctions on any foreign bank that facilitates transactions with NIOC, according to the sanctions law.

But the new penalties will not apply to countries that have been granted "exceptions," or waivers, to the sanctions because they have significantly cut their purchases of Iranian oil.

The United States this year issued 180-day waivers for all of Iran's major crude buyers. This month it renewed waivers for Japan and 10 EU countries, while exceptions for China and India are due to be reviewed in coming months.

A sanctions lawyer said the determination could make foreign banks skittish about taking on business that while technically allowed, could hurt ties with the U.S. government or U.S. banks.

"To me, the more significant impact is the stigmatization of NIOC," said Behn Dayanim, a lawyer with Axinn, Veltrop & Harkrider LLP in Washington who advises clients on U.S. sanctions law.

"The upside isn't worth the downside if you actually end up inadvertently committing a violation," Dayanim said in an interview. (Editing by James Dalgleish and Mohammad Zargham)

Source: http://news.yahoo.com/u-links-irans-state-oil-company-revolutionary-guards-184354564--finance.html

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Biden, Odierno support military children

NATIONAL HARBOR, Md., Oct. 14, 2011 -- Two staunch military family advocates today spoke on behalf of military children, citing the challenges and stresses they endure to an audience of child support professionals from across the nation.

Speaking at the Office of Juvenile Justice and Delinquency Prevention's national conference here, Jill Biden, wife of Vice President Joe Biden, and Army Chief of Staff Gen. Raymond T. Odierno noted the importance of mentorship and support for military children as they navigate the frequent moves, deployments and separations brought on by more than a decade of war.

"As a teacher and a military mom and grandmother, I have seen firsthand what a big difference a great mentor can make in the lives of our nation's military children," Biden told the audience of juvenile justice and child protection professionals. Her son, Beau, serves in the Delaware Army National Guard.

Biden cited a new program that's already making a difference in military children's lives. Earlier this week, she explained, the Justice Department announced a partnership with the Defense Department to award $20 million to organizations that provide mentoring programs and services to children with a military parent. Among the award recipients are the Boys and Girls Clubs of America, Big Brothers Big Sisters, and the National 4-H Council.

"These mentors and so many other individuals and groups across this country are showing all Americans that there are countless ways to help our military families -- some large and many small, but all important," Biden noted.

Last year, President Barack Obama directed federal agencies to work together on a government-wide approach to supporting military families, Biden said, and "this mentoring initiative represents a powerful response to that call to action."

It's also a fitting example of agencies "Joining Forces," she said. First Lady Michelle Obama and Biden launched that initiative earlier this year to encourage all sectors of society to honor and support military families.

Military children need and deserve this support, she said, as they endure unique challenges and stresses, from multiple moves and schools to deployments and separations.

Biden recalled meeting a teenager whose father had deployed to Afghanistan with the Illinois National Guard. The girl gave Biden an essay she had written about that deployment.

In her essay, the teen said a teacher called her to the office one day. Her first thought was something bad had happened to her dad. "When I got to the office," she wrote, "I saw my mom was there, and she was crying, which made me start crying right away. I asked what was wrong, and she told me that my dad was okay, but we had lost four of our soldiers. I remember crying for days."

The teen and her brother, Biden noted, were the only military children in that school.

"Unfortunately, their story is not unique," she said. "There are approximately 700,000 children throughout the country who have parents serving in the National Guard and reserves -- and so many of them do not live anywhere near a military base.

"As a mom of a National Guardsman," she added, "I know just how important it is for a teacher, a counselor or a fellow classmate to reach out and show support and understanding."

Biden encouraged the audience to reach out to military families.

"Think about how you can take part in bringing some stability, guidance and friendship into their lives," she said.

Odierno echoed Biden's call to support military children and their families. The military has shouldered the burden of multiple deployments and separations for years now, he said, which affects the family members just as it affects the service members.

The nation must maintain its commitment to these families, the general said, especially the families of the fallen and those who are caring for service members wounded in combat.

Odierno noted that more than 4,500 soldiers have died while serving in Iraq and Afghanistan, and more than 32,000 have been injured, with 9,000 of those requiring long-term care.

"The one thing I'm always concerned about with these factors -- repetitive deployments, casualties, death -- is the impact it has on our children," he said. "What are we doing to help them to cope? What are we doing to help them to overcome?"

Programs such as the Defense and Justice departments mentorship partnership will help to ensure military children adapt and excel in the years ahead, Odierno said, but still more help is needed.

"We need engagement from organizations not normally involved in military issues," the general said, "to help us, to provide us expertise, to fill the gaps between where our government programs are able to help our families and where they cannot."

Community support also is needed, Odierno noted, particularly for reserve forces that are geographically dispersed throughout the nation. "We need to be able to reach out to them, to reach out to their children to help them," he said.

Odierno said he'd also like to forge a relationship with nonprofit organizations that support military families so there's better access and coordination, and to other departments and agencies that provide care for children to ensure they're incorporating military family members in their programs.

The general noted his career, which spans 35 years, has spurred 23 moves. His oldest child, he added, attended four different high schools. "First and foremost," he said, "we need continued assistance to school-age children to support seamless transitions between schools."

While much work remains to be done, Odierno said he's grateful for the support Americans have so freely given over this past decade of war. "I've been so impressed by the generosity of American people, that [they] want to reach out, they want to help, they want to assist," he said. "They want to do whatever they can to help our families."

Meetings such as this one, he told the audience, will help to channel this goodwill toward families and "organize ourselves so we can take that generosity, that commitment, that willingness to help ? to get it synchronized and integrated so we can provide best care for all of our children," he said.

Source: http://www.army.mil/article/67367/Biden__Odierno_support_military_children/

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Background note: the European Union at the 67th UN General Assembly (24 - 28 September, New York)

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Source: http://www.consilium.europa.eu/press/press-releases/latest-press-releases/newsroomloaddocument.aspx?id=1823&lang=English&directory=en/ec/&fileName=132527.pdf

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Introduing Power Up! - Quirky Kid Clinic

While Australia?s elite sportsmen are aiming for top form in the footy finals, young Australians are also striving to achieve their best: It?s now the ?business end? of the year, when kids take to the field in sports finals, school students knuckle down to study for final exams, and young performers prepare for end-of-year eisteddfods.

But how to get the most out of high achievers without overdoing it? A new resource from one of Australia?s leading child psychology practices, The Quirky Kid Clinic? helps young people perform at their best, while maintaining balance and perspective, and not getting burnt out.

?Power Up!? is a step-by-step program that enables schools and clubs to adopt the type of performance psychology used by elite athletes, performers and musicians. Young people striving to perform at high levels in sports, performance, music or academia (including end of year exams) can benefit from these techniques. They include goal setting, self-talk, imagery, arousal regulation, focus and competition planning.

Quirky Kid Clinic?s principal child Psychologist, Kimberly O?Brien says: ?Know- ing how to reach your performance peak is more effective than endless hours of coaching. Power Up! is about avoiding burn out and enjoying what you do best?.

Power Up! will be distributed by the Australian Council of Educational Research. ACER?s National Sales Manager Eirini Lamni says the program is an ?innovation in the way we approach high performing kids. By focusing on the path towards goals rather than just the end-point, young people are armed with useful, healthy strategies to perform at their best. It?s a great resource.?

Power Up! will be launched on the 26th of September at the Sydney Academy of Sport and Recreation, in partnership with Football United. Football United organaises soccer matches, tournaments and camps, providing opportunities for young refugees, or kids from disadvantaged backgrounds to socialise, form networks, and to excel on the sports field.

More information about Power Up! is available at http://quirkykid.com.au

To register to a workshop visit our workshop registration page

Source: http://childpsychologist.com.au/news/introduing-power-up

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