If you are an affiliate the FTC Guidelines will impact upon your business regardless of where you are based. The guidelines came into force on 12/1/09.

The impact is in four main areas:-

Material Connection Disclosure – Whereby, any affiliate linking to a merchant website within a product review or otherwise should clearly state if there is any material benefit from such a connection. Furthermore, "The disclosure must be sufficient to alert the consumer that of the connection between the endorser and the product."

As, such we have added a Review Disclosure Policy page to our ANC Site together with a link to it from each of our product review pages.

Product Misrepresentation – You must not make unsubstantiated claims about a product or service in terms of what is on offer, for what price and what results can be obtained. Particular care should be given to when results achieved by a small sub-set of users are claimed as being typical

Customer Testimonials – These should be both current and regularly updated. Again any claims of results obtained should not be claimed or implied as being typical.

Affiliate Management – If you are a merchant / product or service provider with your own affiliates you may need to set out terms and conditions that your affiliates adhere to in relation to the above and you may need to be able to show that you periodically review your affiliate's sites and document any findings, feedback, enforcement, etc.

I am not in a position to give you any legal advice regarding the FTC guidelines but strongly recommend you implement a disclosure policy on all your affected websites, blogs, etc.

I also recommend you take time to watch the following video by Jim Edwards of an interview he conducted with a senior FTC representative.

http://jimedwards.s3.amazonaws.com/ftc-advertising-interview/index.htm