FTC Staff Paper Highlights the Threat of Stealth Advertising to Children

What is Stealth Advertising?

Stealth advertising (aka blurred advertising and guerilla advertising) is a term that describes a variety of advertising methods in which consumers are often unaware that they are being subjected to advertising. Product placement in movies is a common example of stealth advertising, but it also includes subliminal advertising, in which visual or auditory stimuli that the conscious mind cannot perceive is inserted into TV commercials or popular songs.

The primary objective of stealth advertising is not to drive immediate sales, but rather to develop curiosity and excitement that makes consumers more susceptible to direct advertising in the future. In short, it is a form of mind control, in that it influences consumer decisions while leaving consumers unaware that they are being manipulated.

The FTC and Stealth Marketing

Part of the Federal Trade Commission's stated mission is to protect consumers from unfair or deceptive business practices, so protecting consumers from stealth advertising practices falls well within the agency’s wheelhouse, and few consumers are more vulnerable to stealth advertising than children. 

On September 14, 2023, the FTC announced the release of a new staff paper called “Protecting Kids from Stealth Advertising in Digital Media,” which highlights the agency’s concerns that stealth ads presented to children online and in immersive digital environments like gaming and virtual reality platforms, are difficult if not impossible for kids to distinguish from regular content.

At the FTC event, the presentation focused on extensive research revealing the many types of stealth ads young consumers are exposed to on a daily basis, including advertising messages camouflaged in influencer social media posts, unboxing videos, online gaming, and in virtual reality worlds. According to the FTC’s research, children lack the capability to recognize and assess stealth ads, which can potentially result in deception and a myriad of consequences, including physical, financial, and privacy-related injuries.

“We now live in a world where kids spend many hours a day online, often in immersive environments where ads and content are deliberately difficult to distinguish,” said Samuel Levine, Director of the FTC’s Bureau of Consumer Protection.

The FTC Staff Paper included specific recommendations that advertisers, content creators, platforms, and others should follow to reduce the likelihood of young consumers being deceived or otherwise harmed:

1. Do not blur advertising: Separate entertainment from ads using clear visual/verbal cues for kids.
   
2. Timely, clear disclosures: Give verbal/written disclosures when introducing products, but don't rely on them alone.
   
3. Create clear ad icons: Input visible, simple icons that notify kids of sponsored content, such as #Ad or #BrandNameSponsership.
   
4. Education: Educate children, parents, and teachers about how digital ads work to help kids recognize and evaluate it whenever it appears.
   
5. Tools and Controls: Platforms should offer more tools and controls to parents to help their young children avoid blurred ads.

While each one recommendation would make a difference, the FTC paper makes it clear that relying on just one of them will not offer sufficient protection to the children it aims to protect.    

Advertisers and marketers employing stealth advertising methods could face consequences under the FTC Act if they deceive or act unfairly towards kids. The Blacklist Academy offers a range of marketing compliance courses, to sidestep possible lawsuits. 

As for Sidney Gottlieb, after MK-ULTRA shut down, he went on to lead a CIA program that created poisons, high-tech weapons, and other spy gadgets, not unlike a sadistic, amoral version of “Q” from the James Bond films.