"The Federal Trade Commission (FTC) recently settled an enforcement action with Paddle.com, a U.K.-based payments company, and its U.S. subsidiary (“Paddle”). The settlement resolves claims against Paddle for violation of the Federal Trade Commission Act, Telemarketing Sales Rule, and Restore Online Shoppers’ Confidence Act. The settlement is notable for the FTC’s focus on Paddle’s use of a “merchant of record” (MOR) model for payment processing."