The Consumer Protection Act and the Antipyramid Promotional Scheme Act were the main targets of the inquiry.

After completing its investigation, the Washington AG’s Office made the decision to take the case to trial. Paparazzi chose to reach a settlement rather than contest Washington’s accusations.

Paparazzi agreed to a thirty-one-day injunction as part of the settlement’s conditions. According to the injunction, paparazzi are not allowed to sell, advertise, promote, or provide a business opportunity to anyone living in Washington or inside the state.

Paparazzi are forbidden from promoting a “business opportunity” that bases a consultant’s compensation or eligibility for compensation primarily on that consultant’s or another consultant’s purchase of goods or services following the thirty-one-day injunction period;

has to make any required purchases in order to be eligible for a promotion or payment.

determines a consultant’s pay, qualifications, or status based on one of the following: (1) the number of persons in their downline; (2) the depth of their downline; (3) their personal volume; or (4) the volume of purchases made by the consultants in their downline.

In other words, two characteristics of an MLM pyramid scam are “pay to play” and autoship recruiting.

Nothing in Paparazzi’s remuneration scheme indicates that retail is a priority, except from conventional retail commissions.

Because of the shallow generational incentives and residual income, Paparazzi Accessories affiliates are more concerned with hiring than with using leverage.

And once again, Paparazzi Accessories’ pay structure does little to discourage this conduct. Additionally, when the monthly affiliate orders mount, the corporation makes no indication of whether it confirms retail sales are occurring.

Paparazzi are allowed to operate a compensation scheme that specifies the minimum monthly retail sales required to be eligible for the plan.

Since thirty-one days haven’t gone by, it’s still unclear whether Paparazzi will carry out this plan or go on with their pyramid business, which has little to no retail sales outside of Washington.

If paparazzi want to continue working in Washington, they must also meet the following requirements: 

1. provide an Income Disclosure Statement to potential consultants; refrain from hiring new consultants for seven days after the receipt of the statement (no communication is permitted during this cooling-off period);
2. stop making payments “based on consultant purchases”; gather sales information from consultants; use “random and targeted audits” to confirm stated retail sales;
3. a 60-day cooling-off period that permits new consultants to return any inventory of products they have acquired;
4. Establish a 12-month buy-back program for inventory that has been purchased; stop making false claims about Paparazzi as an MLM opportunity, such as when it comes to income, the time and effort needed, and the blame for business failure on consultants; and submit to compliance monitoring through 2030. 
   
   

The conclusion is that Paparazzi must concentrate on retail sales if they decide to relaunch their multilevel marketing business in Washington state.

Paparazzi have essentially acknowledged that they are unable to function lawfully if you are reading this piece on March 30, 2025, or around that time, and they haven’t started up again in Washington state.

Former Washington-based paparazzi consultants will be compensated with the $1.9 million judgment from Paparazzi.

In the near future, Attorney General Nick Brown will distribute compensation totaling an average of $180 to 7,100 Washingtonians who sold jewelry for the corporation.

Although pyramid schemes are prohibited by federal law, it is uncertain whether the FTC will take any action. Unfortunately, the FTC is prioritizing political goals that provide a quid pro quo above consumer protection at the time of publishing.