Investor Alert: Beware of Paid-To-Click (PTC) Scams


The SEC’s Office of Investor Education and Advocacy is warning investors about investment scams conducted through online paid-to-click (PTC) programs.

Getting paid to click on online ads may sound like an easy way to make money, but can also result in losing money. Online paid-to-click (PTC) programs often promise investors a share of the program’s profits in exchange for paying an upfront fee or buying products. For example, a PTC program may claim you can share in its profits if you buy “ad packs” or other advertising products. These PTC programs might promise you advertising services such as displaying your ads on their network or guaranteeing traffic to your website if you become a member or buy their ad packs. They might even promise to share their profits with investors who have nothing to advertise – simply buy the ad pack and share in the profits.

Before you purchase a membership or any advertising product from a PTC program, be aware that some PTC programs may be scams. For example, some PTC programs may be Ponzi schemes, where money from new investors is used to pay fake “profits” to earlier investors. Don’t let your guard down just because a PTC program claims it is not an investment scheme. Look out for these red flags:

  • Easy money. Be skeptical if you are offered high returns in exchange for merely purchasing products or for trivial tasks such as clicking on a certain number of online ads each day. Any investment opportunity that sounds too good to be true probably is.
  • Required upfront payments. Be wary if you are asked to pay money upfront to participate in a PTC program, even if it’s supposedly for a membership plan or product purchase. Why would a company require you to pay a membership fee or to buy a product, for the “opportunity” to click on ads?
  • No revenue from genuine products or services. Ask to see documents, such as financial statements audited by a certified public accountant (CPA), showing that the PTC program generates real revenue from selling products or services. If the PTC program has no revenue from customers other than its own members, any returns you receive are likely from other investors’ buy-in fees.
  • Virtual address. Verify that the business address listed for the PTC program is legitimate. For example, enter the address into an online search engine and be skeptical if the results suggest it is not a valid address or that the PTC program does not have legitimate operations at the location.
  • Withdrawal problems. If you have trouble withdrawing your money or are required to reinvest your profits, it may be because there is not enough money coming in from new investors to cover earlier investors’ withdrawal requests.

In two recent enforcement matters, the SEC charged companies for conducting Ponzi schemes through purported online advertising programs:

  • In SEC v. Traffic Monsoon, the SEC brought an enforcement action against a purported online advertising company and its operator for conducting a Ponzi scheme. The operator allegedly solicited investors through the company’s website and YouTube videos to purchase advertising products called “AdPacks.” According to the SEC’s complaint, each AdPack provided advertising benefits to the investor (20 clicks to the investor’s banner ad and 1,000 visitors to the investor’s website) and the ability to share in the company’s profits. The SEC alleged that more than 162,000 investors purchased approximately $207 million in AdPacks. More than 99% of the money that the company distributed to investors allegedly came from investors purchasing new AdPacks.
  • In SEC v. Pedro Fort Berbel, et al., the SEC charged a company and its principal officer with operating a Ponzi scheme through its purported online advertising businesses, MLM Shop, The Business Shop, and Fort Ad Pays. The defendants allegedly solicited investors through online posts and videos (in languages including English, Spanish, and French) on the defendants’ websites. In its complaint, the SEC alleged that these posts and videos claimed that investors could share in the businesses’ profits. The businesses allegedly required investors to purchase a plan or an advertising product. According to the SEC’s complaint, one of the businesses offered potential returns of 120% in exchange for purchasing an “Ad Pack” for as little as one dollar and clicking on four banner ads each day (or alternatively, investors could purchase a plan that did not require any action). The defendants allegedly raised $38 million from investors and kept at least $7 million for themselves to pay for a Florida private home, automobile expenses, and private plane charters, and to fund other businesses. Roughly 99% of the money generated by the defendants’ businesses allegedly came from other investors’ payments.

Additional Resources

View document in SPANISH – translated version,
available at

View document in FRENCH – translated version,
available at

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The Office of Investor Education and Advocacy has provided this information as a service to investors.  It is neither a legal interpretation nor a statement of SEC policy.  If you have questions concerning the meaning or application of a particular law or rule, please consult with an attorney who specializes in securities law.

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